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.
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.