What Is Form 12153? How to Request a Collection Due Process Hearing

Form 12153 is the IRS form used to request a Collection Due Process (CDP) hearing after you receive certain IRS collection notices. Filing Form 12153 on time can protect your appeal rights, generally suspend proposed levy action for the tax periods under appeal, and give you the chance to discuss payment options or challenge the collection action before the IRS moves forward.

In this guide, you’ll learn what Form 12153 is, when to file it, how the CDP hearing process works, what happens after the IRS receives your request, and what options may be available if you miss the deadline.

What Is Form 12153?

Form 12153 lets taxpayers request a Collection Due Process hearing after receiving a qualifying IRS notice. When levy action is the subject of the hearing, a timely request generally suspends the proposed levy for the tax periods under appeal while the Independent Office of Appeals reviews the case. The hearing also gives you an opportunity to discuss collection alternatives or challenge the proposed action.

Form 12153, officially called the Request for a Collection Due Process or Equivalent Hearing, is the form taxpayers use to request Appeals review after receiving a qualifying CDP notice. You can use this IRS form after receiving a Final Notice of Intent to Levy or a Notice of Federal Tax Lien filing. Filing the form does not erase your tax debt, but a timely request preserves your right to Appeals review and possible U.S. Tax Court review of the CDP determination.

A Collection Due Process hearing is different from an IRS audit or an audit reconsideration. Instead of reviewing how your tax return was prepared, the hearing focuses on whether the IRS followed the correct collection process and whether another tax resolution option makes more sense. Depending on your situation, you may discuss an installment agreement, an Offer in Compromise, hardship status, or other collection alternatives.

You cannot always use a CDP hearing to challenge the amount of tax you owe. You may generally dispute the underlying tax liability only if you did not receive a statutory notice of deficiency and did not otherwise have a prior opportunity to dispute the liability through IRS Appeals or a court.

Expert insight: We often see creators wait until a wage levy or bank account levy seems close before opening IRS notices. In many cases, acting during the 30-day appeal window gives taxpayers more options and stronger legal protections than waiting until enforced collection begins.

What IRS Notices Allow You to File Form 12153?

You may file Form 12153 when the IRS sends a notice that specifically provides Collection Due Process hearing rights. The notice should identify the deadline and the address where the hearing request must be sent.

Do not send Form 12153 to the payment address or directly to the IRS Independent Office of Appeals. If you want to submit the request by fax, call the number on the notice to confirm whether fax submission is available and which number to use.

Common notices and situations include:

IRS Notice or Collection Action	What It Means	Can Form 12153 Be Used?
LT11 or Letter 1058, Final Notice of Intent to Levy and Notice of Your Right to a Hearing	The IRS is providing CDP rights before proceeding with levy action for the listed tax periods.	Yes
Letter 3172, Notice of Federal Tax Lien Filing and Your Right to a Hearing	The IRS filed a Notice of Federal Tax Lien and is providing CDP rights concerning that filing.	Yes
Certain post-levy notices	The IRS already completed a levy in a situation where CDP rights are provided after the action, such as certain state tax refund or jeopardy levies.	Yes, when the notice specifically provides CDP rights
CP504 or another balance-due notice	The IRS warns that collection may continue, but the notice may not provide the standard pre-levy CDP rights discussed here.	Not by itself unless the notice specifically states that CDP rights apply
General collection correspondence	The notice may request payment or provide other appeal options without offering a CDP hearing.	Only when the notice expressly provides CDP rights

Read the notice carefully before filing. The notice itself should state whether you may request a Collection Due Process hearing, the response deadline, and where the request must be sent. If you recently received an LT11 Notice, read our guide explaining what the notice means and what may happen before the IRS begins levy action.

When Should You File Form 12153?

You should file Form 12153 by the deadline shown on your qualifying IRS notice, which is generally 30 days from the notice date. Filing within this deadline preserves your Collection Due Process rights and generally suspends proposed levy action for the tax periods under appeal while your appeal moves through the IRS Independent Office of Appeals.

Use the exact response deadline shown on the notice rather than calculating the deadline from the day you opened the mail. Missing that deadline changes the type of hearing you can request and limits some of your appeal rights. Many taxpayers lose valuable legal protections simply because they wait too long to respond.

If you miss the deadline, you may still request an Equivalent Hearing within the applicable one-year filing period. Check Form 12153 and your notice for the exact deadline because the calculation differs between levy and lien cases. An Equivalent Hearing allows the Independent Office of Appeals to review your case, but it does not provide the same protections as a timely Collection Due Process hearing. For example, an Equivalent Hearing generally does not stop IRS collection activities, and you cannot appeal the decision to the U.S. Tax Court.

What Happens If You Miss the CDP Deadline?

The difference between a CDP hearing and an Equivalent Hearing can affect your options.

Timely Collection Due Process Hearing	Equivalent Hearing
Requested by the deadline shown on the CDP notice, generally within 30 days	Requested after the CDP deadline but within the applicable Equivalent Hearing period
Generally prohibits levy action in most cases and suspends the IRS collection period while the case is pending	Does not prohibit levy action or suspend the IRS collection period
Generally allows you to seek U.S. Tax Court review after a Notice of Determination	Does not provide the same right to Tax Court review of the collection decision
Preserves full CDP hearing rights	Provides more limited appeal rights

For a levy notice, the Equivalent Hearing request generally must be made within one year of the CDP levy notice date. For a lien notice, the deadline is generally one year plus five business days from the filing date of the Notice of Federal Tax Lien. If you receive an IRS notice, read it carefully and note the filing deadline. Sending Form 12153 through certified mail or another trackable delivery method helps document when you submitted your hearing request.

How Do You Complete and Submit Form 12153?

Complete Form 12153 carefully and send it to the address for requesting a hearing shown on your CDP notice. Do not send it to the payment address or directly to the Independent Office of Appeals.

Follow these steps:

1. Confirm that your notice provides CDP rights. Identify the exact deadline and the tax periods covered by the notice.
2. Select the collection action you are appealing. Check the box for a filed Notice of Federal Tax Lien, a proposed or actual levy, or both when applicable. Check the Equivalent Hearing box when your request does not qualify as timely and you want an Equivalent Hearing.
3. Enter the taxpayer and tax information. Provide the requested names, taxpayer identification numbers, contact details, tax types, form numbers, and tax periods. Include a copy of the CDP notice to help the IRS match the request to the correct case.
4. Explain every reason for your request. State why you disagree with the collection action and identify the outcome you want Appeals to consider. Attach additional pages when the space on the form is not enough.
5. Prepare supporting financial records. If you are requesting an installment agreement, Offer in Compromise, or currently unable-to-pay status, Appeals will generally need Form 433-A for individual finances, Form 433-B for business finances, or both when appropriate. Submitting these forms with Form 12153 is not required, but early submission may help Appeals review your proposed collection alternative more quickly.
6. Sign and submit the request. Follow the signature instructions on Form 12153. Send the completed form, a copy of the CDP notice, and relevant attachments to the hearing-request address on the notice. Keep copies and proof of the submission date.

If you want to send the request by fax or are unsure which address to use, call the telephone number shown on the CDP notice before submitting it.

How Does Form 12153 Protect Your Appeal Rights?

Form 12153 gives you the opportunity to request Appeals review after receiving an IRS notice that provides Collection Due Process hearing rights. Filing on time protects your appeal rights and creates a formal review through the Independent Office of Appeals.

A timely CDP request also suspends the IRS’s ten-year collection period while the hearing and any permitted judicial review remain pending. The suspended time is generally added to the collection period. An Equivalent Hearing does not suspend that period.

The hearing allows an Appeals Officer to review whether the IRS followed collection procedures correctly. You can also discuss whether the proposed levy or federal tax lien filing is appropriate based on your financial situation. If you disagree with the collection action, you have the opportunity to explain why and provide supporting documents.

Depending on your circumstances, you may propose a collection alternative or raise another eligible issue, such as:

• An installment agreement
• An Offer in Compromise
• Currently Not Collectible status because of financial hardship
• Penalty abatement, when eligible
• Innocent spouse relief, if the tax issue involves a joint return

The Appeals Officer reviews the information from both you and the IRS before issuing a written decision called a Notice of Determination. If you requested a timely Collection Due Process hearing and disagree with that determination, you generally have 30 days to petition the U.S. Tax Court.

Professional perspective: A Collection Due Process hearing can be an important time to present updated financial information. Waiting until after levy action begins can make negotiations more difficult because the IRS may already have started collecting from wages, bank accounts, or other assets.

What Information Should You Include with Form 12153?

A complete Form 12153 gives the IRS Independent Office of Appeals enough information to understand your position and evaluate possible collection alternatives. Supporting documents can strengthen your request and reduce delays during the review process.

The form asks for basic information, including your name, Social Security number or taxpayer identification number, current contact information, the tax periods involved, and the IRS notice you received. You will also explain why you disagree with the collection action or identify the collection alternative you want the Appeals Office to review.

Depending on your case, you may also include documents such as:

• A financial statement showing income, expenses, assets, and liabilities
• Proof of financial hardship
• Form 8857, Request for Innocent Spouse Relief, and relevant supporting records

• Documents supporting penalty abatement
• Payment plan proposals
• Copies of correspondence related to the tax liability

Supporting documents do not replace Form 12153, but they help the Appeals Officer understand your financial position. Missing information may lead to additional requests before the hearing moves forward.

For self-employed individuals, including content creators, organized financial records often make these discussions much smoother. Income from multiple platforms, business expenses, estimated tax payments, and prior payment arrangements all help create a clearer picture of your ability to resolve the tax debt.

What Is the Difference Between a Tax Lien and a Tax Levy?

A federal tax lien protects the government’s legal interest in your property, while a tax levy allows the IRS to take property or money to satisfy unpaid taxes. Understanding this difference helps explain why Form 12153 can be so valuable before collection action advances.

A Notice of Federal Tax Lien alerts creditors that the IRS has a legal claim against your property because of unpaid tax liability. Although a lien does not immediately take your assets, it may affect financing, business transactions, or the sale of property. The lien generally remains until the tax debt is paid or otherwise resolved.

A tax levy is much more direct. After completing the required notice process, the IRS may levy funds from your bank account, garnish wages, or seize certain other assets. When a proposed levy is the subject of a timely CDP request, levy action is generally suspended for the tax periods under appeal while the case is pending.

The table below highlights the difference:

Federal Tax Lien	Tax Levy
Creates a legal claim against property	Takes money or property
May affect financing or asset sales	Can affect wages, bank accounts, and other assets
Generally arises after the IRS assesses the tax, sends a bill, and the taxpayer fails to pay	Begins after levy procedures are complete
Can be appealed through Collection Due Process when eligible	A timely CDP request generally suspends levy action for the appealed tax periods

What Happens After You File Form 12153?

After the IRS receives Form 12153, it reviews whether your request was timely and transfers eligible cases to the Independent Office of Appeals. When levy action is the subject of a timely Collection Due Process hearing request, the proposed levy is generally suspended for the tax periods under appeal while the case is pending.

The IRS first checks whether your hearing request meets the filing deadline and whether it relates to a qualifying notice. If the request is complete, the case moves to the Independent Office of Appeals, where an Appeals Officer reviews the facts and any supporting documents you submitted. The Appeals Office operates separately from the IRS Collection division, which helps provide an independent review of your case.

The time required to complete the appeals process varies based on the issues involved, the documents needed, and the Appeals Office’s workload. During the review, you may receive requests for additional financial information or supporting records. Responding quickly helps prevent unnecessary delays and gives the Appeals Officer the information needed to evaluate your request.

What Can You Discuss During a CDP?

A Collection Due Process hearing is more than an appeal. It is also an opportunity to work toward a practical tax resolution that fits your financial situation.

You may discuss topics such as:

• An installment agreement
• An Offer in Compromise
• Currently Not Collectible status because of financial hardship
• Penalty abatement, when available
• Innocent spouse relief
• Whether the IRS followed the correct collection procedures
• Collection alternatives that are less burdensome than a levy

Your Appeals conference may take place by telephone or through correspondence. An in-person conference may also be available if you qualify under IRS Appeals procedures.

Expert insight: Taxpayers sometimes focus only on stopping a levy. In practice, the hearing can be an important opportunity to present updated financial information and propose a long-term solution before collection action resumes.

How Can You Strengthen Your Form 12153 Request?

A well-prepared Form 12153 gives the Appeals Officer a clearer understanding of your financial situation and the collection alternative you want the IRS to review. Complete information often leads to a smoother appeals process.

Simply stating that you cannot pay your tax bill rarely provides enough information. Instead, explain your situation clearly and include documents that support your position. If you believe the proposed collection action creates financial hardship, show how it affects your ability to pay necessary living or business expenses.

For example, a content creator who earns income from OnlyFans, sponsorships, and affiliate marketing may have income that changes from month to month. Recent bank statements, bookkeeping records, estimated tax payments, and profit and loss reports can help explain why a standard payment plan may not fit the taxpayer’s current financial condition. Clear documentation gives the Appeals Officer a stronger basis for evaluating a collection alternative.

Documents That May Help Support Your Request

Depending on your circumstances, you may include:

Supporting Document	Why It Helps
Recent bank statements	Shows available funds and cash flow
Financial statement	Explains income, expenses, assets, and liabilities
Profit and loss report	Supports self-employed income
Payment records	Confirms recent tax payments
Hardship documentation	Supports hardship status requests
Penalty relief documents	Supports penalty abatement requests

Only include documents that relate to your case. Organized records make it easier for the Appeals Officer to review your request.

What Are the Most Common Form 12153 Mistakes?

Many taxpayers lose valuable appeal rights because they miss deadlines, submit incomplete information, or misunderstand what a Collection Due Process hearing can accomplish. Most of these issues are preventable with careful preparation.

One of the biggest mistakes is waiting too long to respond after the IRS sends a Final Notice of Intent to Levy or a Notice of Federal Tax Lien filing. Missing the CDP deadline may limit you to requesting an Equivalent Hearing within the applicable filing period. A late CDP request is not automatically treated as an Equivalent Hearing request, so you must check the Equivalent Hearing box or otherwise request one in writing. An Equivalent Hearing does not provide the same right to petition the U.S. Tax Court over Appeals’ collection decision.

Another common issue is failing to explain the reason for requesting the hearing. If you want an installment agreement, hardship status, or another collection alternative, identify that request clearly and provide supporting financial information when appropriate.

Other mistakes include:

• Mailing the form to the wrong IRS address instead of the address listed on the notice
• Forgetting to sign the form
• Failing to identify the tax periods or include a copy of the CDP notice

• Providing incomplete contact information
• Ignoring IRS requests for additional documents during the appeal

Small errors can delay the review process, so it helps to review the form carefully before sending it.

FAQs

What is Form 12153 used for?

Form 12153 is used to request a Collection Due Process hearing or an Equivalent Hearing after receiving an IRS notice that provides CDP appeal rights. The hearing gives taxpayers the opportunity to challenge collection actions, discuss payment options, and protect their appeal rights. When levy action is the subject of the hearing, filing on time generally suspends the proposed levy for the tax periods included in the appeal while the case is pending.

When should I file Form 12153?

File Form 12153 by the exact deadline shown on your qualifying CDP notice, which is generally within 30 days. A timely request preserves your CDP rights and generally suspends levy action for the appealed tax periods. If you miss the deadline, you may still qualify for an Equivalent Hearing within the applicable one-year filing period, but levy action is not prohibited, and your appeal rights are more limited.

What happens after filing Form 12153?

After filing Form 12153, the IRS reviews whether the request is timely and relates to a qualifying CDP notice. Eligible cases are forwarded to the Independent Office of Appeals, where an Appeals Officer reviews the collection action, supporting documents, and any resolution you propose. A timely CDP hearing generally concludes with a Notice of Determination, while an Equivalent Hearing provides more limited review rights.

Does Form 12153 stop an IRS levy?

A timely Form 12153 request generally suspends a proposed IRS levy for the tax periods included in the CDP hearing. The suspension usually remains in place while Appeals reviews the case and during any timely judicial review. An Equivalent Hearing generally does not suspend levy action or the IRS collection period.

Conclusion

Form 12153 gives taxpayers an opportunity to request a Collection Due Process hearing after receiving an IRS notice that provides CDP rights. Filing by the deadline protects important appeal rights and generally suspends proposed levy action for the tax periods under appeal while the Independent Office of Appeals reviews the case. The hearing also allows you to discuss payment arrangements and other collection alternatives that better match your financial situation. Acting early often gives you more options than waiting until collection activity has already started.

At The OnlyFans Accountant, we help creators understand IRS collection notices, evaluate appeal rights, and choose practical tax resolution options based on their situation. We assist with Form 12153, payment plans, financial documentation, and other IRS collection matters so you can move forward with confidence. Contact us today to discuss your IRS notice and find the next step that best fits your situation.