The Internal Revenue Service Collection Due Process Hearing ( CDP )
The Collection Due Process hearing process begins when there is a :
1.  Notice of Federal Tax Lien and Your Right to a Hearing Under IRC 6320
2. Final Notice – Notice of Intent to Levy and Your Right to a Hearing
3. Notice of Jeopardy Levy and Right of Appeal
4. Notice of Levy on Your State Tax Refund
A Collection Due Process hearing allows the taxpayer or his/ her representative to present their objection to the Internal Revenue Services proposed action that is ready to take place.. At the hearing the taxpayer can present a proposed a resolution to a tax problem/debt such as an Installment Agreement, payment agreement Offer in Compromise, or Currently Not Collectible Status.
A taxpayer has only 30 days from the date of the IRS notice to file an Appeal. Once the 30-day window expire, the right to file for a CDP 12153, hearing is gone.
If a taxpayer wants to take their issue to U.S. Tax Court they are generally required to follow the Collection due Process procedures.
The Internal Revenue Service Equivalent Hearing
An Equivalent Hearing is very similar  in part to a Collection due Process hearing. However there are some differences:
1. You can request for an” Equivalent Hearing
2. The IRS will continue collection efforts while an Equivalent Hearing is in progress; and
3. A taxpayer cannot move forward to United States  Tax Court if the appeals decision is adverse to the taxpayer.
The IRS Collection Appeal Process  ( CAP )
The Collection Appeal Process is much broader that the Collection Due Process  in terms of when the procedure is available. Unlike a CDP hearing, if a taxpayer is not successful, the IRS decision will generally stand and the taxpayer cannot continue the fight in U.S. Tax Court. In addition, a taxpayer cannot under any circumstance dispute the existence or amount of a tax debt.
The events that begin this process are;
1. Notice of Federal Tax Lien (NFTL )
2. Notice of Levy 668A, 668W
3. Seizure of Property
4. Denial of Request to Have Seized Property Returned
5. Rejection of Termination of an Installment Agreement, Part Pay Agreement
For the taxpayer to appeal through the Collection Appeals Process, a taxpayer must make an attempt to resolve their tax issue with an IRS manager. If a taxpayer’s issue is still not resolved after speaking or corresponding with an IRS manager, the taxpayer may submit a request for an appeal using Form 9423 Collection Appeal Request.

Fresh Start Tax is one of the premier tax resolution firms in the country. We deal with all types of cases, individuals, business and high dollar corporate entities. We have a staff that specializes in every type of case. Some of our specialties include the following:

• Immediate Tax Resolution and Representation
  

• Offers in Compromise and Settlement

• Back Taxes/  Unfiled or Never filed tax returns
  

• Bank or Wage Levy Garnishments

• Letters of Intent of Notice to Levy

• IRS Tax Audits
• Hardship, part pay agreements
  

• State Sales Tax problems and Resolution

Our company resume:

• Our staff  has over 140 years of professional tax representation experience
  
• On staff are Board Certified Tax Attorney’s, CPA’S, former IRS Agents, Managers and Instructors.
• Former STATE Department of Revenue Manager and Instructor.
  
• We are extremely moral and ethical in ALL our business dealings
• We have the highest rating by the Better business Bureau
• We are fast, affordable and economical
• We are licensed to practice in all 50 States
• We put a premium on client communication.
• National Recognized Veteran Former IRS Agent
  
• Published Tax Expert