This is the form you use to request a CDP hearing when IRS advises that a levy will be or has been issued or an NFTL has been filed.
You will have until the deadline stated in the letter or notice to submit the form and request a CDP hearing with the IRS Independent Office of Appeals (Appeals). See Publication 1660 for a full explanation of the CDP process. If you do not file Form 12153, Request for a Collection Due Process or Equivalent Hearing, at the address listed in your notice by the deadline stated in the letter, you will lose the ability to contest Appeals’ decision in the U.S. Tax Court. If your request for a CDP hearing isn’t timely, you can request an Equivalent Hearing within one year from the date of the CDP notice, but you can’t petition the Tax Court if you disagree with Appeals’ decision.
If the IRS has already issued a CDP notice for that tax debt, then you can still request a hearing with Appeals before or after the IRS files an NFTL, before or after the IRS levies your property, or when the IRS rejects, modifies or terminates your installment agreement. You will need to request a conference through the Collection Appeals Program (CAP), but unlike a CDP hearing, you may not seek review of Appeals’ determination in the U.S. Tax Court. See Publication 594 and Publication 1660 for a full explanation of the IRS collection process and appeal rights.
You can also ask that the IRS manager review your case informally. You can obtain the manager’s name and phone number by contacting the employee listed on your notice. IRS employees are required to give you their manager’s name and phone number. For specifics, see Levies and Liens.