SEE-3 - Specific Areas of Representation (24% of the exam) - Section 3.1

Represent a taxpayer in the collection process, including installment agreements, offers in compromise, currently not collectible status, liens, levies, and Collection Due Process rights.

Represent a taxpayer through the collection process: negotiate installment agreements, evaluate an offer in compromise based on reasonable collection potential, and request currently not collectible status where the taxpayer cannot pay. Distinguish a federal tax lien from a levy, apply the rules for releasing or discharging each, and invoke Collection Due Process hearing rights under a Notice of Federal Tax Lien or Final Notice of Intent to Levy.

Installment agreementOffer in compromiseCurrently not collectibleFederal tax lienCollection Due Process

Practice question for this objective

Free sampleSpecific Areas of Representationhard

Enrolled agent Cassius Okonkwo is helping Delphine Moreau, who within the last week received both a Notice of Federal Tax Lien Filing and Your Right to a Hearing and, separately, a Final Notice of Intent to Levy for the same 2023 liability. Delphine wants a single Collection Due Process hearing that covers both the lien and the proposed levy. Which IRS form should Cassius file to make that combined CDP request?

AForm 9423, the Collection Appeal Request, listing both the lien filing and the proposed levy so that Appeals consolidates them into one Collection Due Process hearing.
BForm 12153, the Request for a Collection Due Process or Equivalent Hearing, identifying both the lien filing notice and the levy notice on the one timely request. Correct
CForm 656, the Offer in Compromise, indicating that the offer doubles as a request for a Collection Due Process hearing on both the lien and the proposed levy.
DForm 843, the Claim for Refund and Request for Abatement, citing both notices so that the abatement claim is processed as a combined Collection Due Process hearing request.

Form 12153 is the request used for a Collection Due Process hearing, and both a lien notice and a levy notice may be listed on one timely form. A Collection Due Process hearing under Sections 6320 and 6330 is requested on Form 12153, which expressly allows a taxpayer who has received both a Notice of Federal Tax Lien filing and a Final Notice of Intent to Levy to identify both on a single timely request so Appeals can hear them together; Form 9423 is the separate CAP request, while Form 656 and Form 843 serve unrelated functions.

Why A is wrong: Form 9423 is a real collection appeal form, but it is the Collection Appeals Program request, not the CDP request, so it cannot be used to obtain the Collection Due Process hearing with its Tax Court review right.

Why B is correct: Form 12153 is the designated form for a Collection Due Process hearing under Sections 6320 and 6330, and a taxpayer who has received both a lien notice and a levy notice may list both on a single timely Form 12153 to have them heard together.

Why C is wrong: Form 656 proposes an offer in compromise and might be a collection alternative raised at a hearing, but it is not the vehicle for requesting a CDP hearing on a lien or levy notice.

Why D is wrong: Form 843 seeks abatement of certain amounts and is plausible because it touches assessed liabilities, but it has no role in requesting a CDP hearing on a lien filing or a levy notice.

See more SEE-3 practice questions, answers explained.

Exam traps in Specific Areas of Representation

Answers that look right on this material and are not. Each one is a distractor from a different question in the SEE-3 bank for this domain.

Request immediate release of the lien under the agreement, because entering any installment agreement satisfies the liability and entitles the taxpayer to a lien release.
Why it is wrong: It is tempting to equate an agreement with payment, but a lien is released when the liability is satisfied or becomes unenforceable, and an ongoing instalment agreement does not pay off the balance, so an immediate release is not available merely because an agreement exists.
Wait for the IRS to issue a Final Notice of Intent to Levy, then file Form 12153 for a Collection Due Process hearing to raise the rejected installment agreement as a collection alternative.
Why it is wrong: Waiting for a levy notice would eventually open a CDP route, but it forces Oksana to invite enforcement she could avoid, and a faster appeal of the rejected agreement is already available without delay.
Request a Collection Due Process hearing on Form 12153 within 60 days of the date of the Letter 1058, because the levy notice gives a 60 day response period before collection may proceed.
Why it is wrong: The 60 day figure is a plausible confusion with other IRS notice periods, but the CDP request deadline tied to a levy notice under Section 6330 is 30 days, so a request lodged on day 45 would be late for a timely CDP hearing.

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