Segal, Cohen & Landis, P.C.
Stop IRS Collection Action — Request a CDP Hearing Now
IRS tax attorneys — Beverly Hills, CA. National representation.
When the IRS files a tax lien or issues a Final Notice of Intent to Levy (Letter 1058 or LT11), you have a critical 30-day window to request a Collection Due Process (CDP) hearing. Requesting a CDP hearing halts IRS collection action while your case is under review.
A CDP hearing is not just a delay tactic. It is a formal proceeding before an independent IRS settlement officer who has authority to accept collection alternatives — offer in compromise, installment agreements, currently not collectible status, penalty abatement, and innocent spouse relief — that a front-line Revenue Officer may have already rejected.
How We Help
Our Approach to Collection Due Process Hearing Attorney
CDP Request Filing
The 30-day deadline to request a CDP hearing is firm. Missing it eliminates your right to judicial review in Tax Court. We file the request immediately — on the same day you retain us — and preserve all your appeal rights.
Collection Alternative Preparation
A CDP hearing is the opportunity to present a collection alternative. We analyze your financial situation and prepare the optimal resolution strategy: OIC, installment agreement, or CNC status.
Appeals Settlement Conference
We represent you at the CDP hearing. The IRS settlement officer is required to consider any collection alternative you propose. We present your financial case and proposed resolution in a structured format that settlement officers can act on.
Tax Court Petition
If the CDP determination is adverse, you have 30 days to petition U.S. Tax Court for review. We preserve this right at every stage.
How It Works
The Resolution Process
Immediate CDP Request
We file Form 12153 (Request for CDP Hearing) the day you retain us. The IRS must cease levy action while the hearing is pending.
Financial Analysis
We gather financial documentation and calculate the optimal collection alternative.
Hearing Preparation
We prepare a written submission for the IRS settlement officer, including financial statements, proposed resolution, and legal arguments.
Settlement or Tax Court
We attend the hearing and negotiate directly with the settlement officer. If an acceptable resolution is not reached, we evaluate Tax Court review.
Ready to Resolve Your Tax Problem?
Our attorneys have helped thousands of clients resolve IRS matters. Your consultation is free and confidential.
Common Questions
Frequently Asked Questions
What notices trigger CDP hearing rights?+
CDP hearing rights are triggered by: (1) Filing of a Notice of Federal Tax Lien (NFTL), and (2) Final Notice of Intent to Levy — specifically IRS Letter 1058, LT11, Letter 3172, or Form 9423.
What is the deadline to request a CDP hearing?+
30 days from the date of the final levy notice or lien filing. This is a strict deadline. Missing it means you lose CDP hearing rights and the ability to petition Tax Court to review the collection action.
Does requesting a CDP hearing stop IRS collection?+
Yes — requesting a CDP hearing stops levy action (bank levies, wage garnishments) while the hearing is pending. However, the IRS may still file a Notice of Federal Tax Lien during a CDP hearing if it has not already done so.
Related Tax Services
Beverly Hills · Los Angeles · National
Segal, Cohen & Landis, P.C.
9100 Wilshire Boulevard, 601 East Tower, Beverly Hills, CA 90212
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