IRS Form 12153: Request for a Collection Due Process or Equivalent Hearing

IRS Form 12153 is your legal request to stop collection action and get an independent review of your tax case before the IRS levies your wages, bank accounts, or other property.

Collection Due Process (CDP) is one of the strongest taxpayer rights built into federal tax law. When the IRS is about to take your money or property, it must first send you a final notice giving you 30 days to request a hearing. Form 12153 is how you make that request — and doing so triggers an automatic hold on collection enforcement while your case is reviewed by the IRS Office of Appeals.

Who Should File Form 12153

You should file this form if you received one of the following notices and disagree with the IRS’s intended enforcement action, believe you qualify for a resolution program, or simply want time to explore your options:

• CP90 — Final Notice of Intent to Levy
• LT11 — Final Notice of Intent to Levy and Notice of Your Right to a Hearing
• CP91 or CP297 — Notice of levy on Social Security benefits
• CP504 — Notice of Intent to Levy (this one triggers an Equivalent Hearing, not a full CDP hearing)
• Letter 3172 — Notice of Federal Tax Lien Filing

If you received a lien filing notice, you can request a hearing to discuss the lien’s appropriateness, subordination, discharge, or withdrawal.

CDP Hearing vs. Equivalent Hearing

This distinction matters significantly. A Collection Due Process hearing must be requested within 30 days of the notice date. It gives you the right to appeal an Appeals decision to Tax Court if you disagree with the outcome.

An Equivalent Hearing can be requested within 1 year of the notice date (after the 30-day CDP window has passed). The hearing process is similar, but you lose the right to appeal to Tax Court. In both cases, the IRS will suspend collection while the hearing is pending.

Miss both windows entirely, and the IRS can proceed with enforcement without any further notice requirement.

How to Complete Form 12153

Personal Information. Fill in your name exactly as it appears on your tax return, your SSN or EIN, address, and a daytime phone number where the IRS can reach you.

Tax Periods. List every tax year and form type mentioned on the notice. If the notice covers 2020, 2021, and 2022 Forms 1040, list all three. Leaving a period off the form means that period is not covered by your hearing request.

Type of Hearing. Check the appropriate box. If your notice is dated within the past 30 days, check CDP. If the 30-day window has passed but the notice is within the past year, check Equivalent Hearing.

Proposed Resolution. This section tells the IRS what you actually want. Your options include an installment agreement, Offer in Compromise, Currently Not Collectible status, innocent spouse relief, or a challenge to the underlying liability (if you have never had a prior opportunity to dispute it). Checking a resolution type signals to Appeals that you are seeking a productive outcome, not just delay.

Your Explanation. Use the back of the form or attach a separate page. Explain concisely why you are requesting the hearing and what facts support your proposed resolution. You do not need to submit a full financial package at this stage — that comes after the hearing is scheduled.

Where to Submit Form 12153

Mail Form 12153 to the address shown on your CDP notice — not a generic IRS mailing address. Use certified mail, return receipt requested, so you have proof of the postmark. The 30-day deadline is a hard cutoff, and missing it by even one day changes your rights.

Common Mistakes to Avoid

• Missing the 30-day deadline. This is the most consequential mistake. Set a calendar reminder the day you receive a CDP notice.
• Not listing all tax periods. Only the periods you include on Form 12153 are covered by the hearing.
• Requesting a hearing with no proposed resolution. The Office of Appeals needs something to work with. Come in with at least a stated preference.
• Assuming the hearing stops all collection permanently. The hold lasts only while the hearing is pending. If Appeals rules against you and you do not appeal to Tax Court, collection resumes.
• Waiting until you lose wages or have a bank account levied. Form 12153 must be filed before the levy — not after.

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