EXPECTATIONS 

Our commitments to you are to: 

•	 Explain your appeal rights and the Appeals 

process 

•	 Listen to your concerns 

•	 Be courteous and professional 

•	 Be responsive (and allow you reasonable 

time to respond to any requests for 

information) 

•	 Be fair and impartial 

It is your responsibility to: 

•	 Listen to our explanation of your appeal 

rights and the Appeals process 

•	 Give us a statement as to how you 

understand the facts and the law, listing all 

issues with which you disagree and why 

•	 Give us any additional information or 


documentation that will help your case


within a reasonable amount of time


•	 Tell us when and how you think your


case should be resolved


•	 Let us know the best time to contact you 

•	 File all required tax returns before the 


hearing


APPEALS - TODAY and TOMORROW 

Want To Learn More About Appeals and Its 

Processes? 

To help you understand the Appeals organization 

and the Appeals process, we have created 

an educational tool utilizing video streaming 

technology. The video stream is designed for 

practitioners, taxpayers, and others that have an 

interest in learning more about Appeals. 

To view the video, go to Internet address: 

www.irs.gov Keyword = Appeals 

The following is just a small sample of the topics 

covered by this video stream: 

•	 The Role of Appeals 

•	 Overview of the Appeals Process 

•	 Introduction to Exam & TEGE Cases 

•	 Introduction to Collection 

•	 Introduction to Alternative Dispute 


Resolution


Windows Media Player version 7 or greater is 

required to view the videos. 

OTHER USEFUL RESOURCES 

Appeals website:


www.irs.gov Keyword=Appeals


IRS website:


www.irs.gov 

Taxpayer Advocate Service: 

1-877-777-4778 

TTY/TTD: 

1-800-829-4059 

IRS Toll Free: 

1-800-829-1040 

Forms and Publications: 

1-800-TAX-FORM 

Department of the Treasury Publication 4165 (Rev. 3-2006) 

Internal Revenue Service Catalog Number 36204Q 

COLLECTION DUE 

PROCESS (CDP) 

MISSION 

OVERVIEW 

EXPECTATIONS 

RESOURCES 

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COLLECTION DUE 

PROCESS (CDP)

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OVERVIEW

EXPECTATIONS

RESOURCES

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Appeals

 An Introduction 

to Collection Due 

Process Hearings 

www.irs.gov Keyword=Appeals 

Appeals

 An Introduction 

to Collection Due 

Process Hearings

www.irs.gov Keyword=Appeals

CDP 
COLLECTION DUE PROCESS (CDP) 

If you are in Appeals for a collection due process 

hearing, IRS issued a notice of intent to levy 

or filed a Notice of Federal Tax Lien to collect 

overdue taxes. The law determines what Appeals 

considers about your case. 

We must consider: 

•	 Whether IRS followed required procedures; 

•	 Issues you raise, like innocent spouse, 

whether the collection action proposed or 

taken is appropriate, and whether there are 

appropriate collection alternatives; and 

•	 The balance between efficient tax 


collection and intrusiveness.


We may not consider: 

•	 Whether you owe the tax if you had a


chance to dispute the liability previously.


•	 Issues a court decided, or that you raised 

in an earlier CDP hearing or other Appeals 

case about this tax. 

IRS procedures determine whether we can 

accept your proposal for collection alternatives. 

If you have filed all required tax returns before 

the hearing, you might qualify for an installment 

agreement or offer in compromise.You may need 

to submit a current financial statement. If you have 

employees and want to compromise withheld 

taxes, you must have timely paid your taxes for at 

least the two most recent quarters. For complete 

information about collection alternatives, please 

review Publication 594. 

If you disagree with our determination in a 

CDP hearing, you may ask a court whether 

Appeals abused its discretion in your case. If you 

requested your hearing late, however, you receive 

an equivalent hearing, but Appeals’ decision 

is final. 

MISSION 

The mission of Appeals is to resolve tax 

controversies, without litigation, on a basis which 

is fair and impartial to both the Government and 

the taxpayer and in a manner that will enhance 

voluntary compliance and public confidence in 

the integrity and efficiency of the Service. Today, 

alternative dispute resolution instead of litigation 

is widely valued and applied in many areas of 

our society. Customers expect more dispute 

resolution options, and Appeals has adapted its 

approach to keep up with the new methods and 

developments. 

Our vision is to explore and apply innovative 

techniques to ensure customer confidence and 

meet customer and employee expectations 

regarding independent resolution services. Our 

goal is to increase confidence in the overall 

fairness of the tax system by providing an 

efficient, independent administrative appeal 

process for all taxpayers. 

OVERVIEW OF APPEALS PROCESS 

If you disagree with the IRS findings in your tax 

case, you can appeal your case to the Appeals 

Office of the IRS. The local Appeals Office is 

separate from and independent of the IRS office 

that proposed the adjustment or collection action. 

An Appeals or Settlement Officer will review the 

strengths and weaknesses of the issues in your 

case and give them a fresh look. Appeals Office 

reviews are conducted in an informal manner, 

by correspondence, telephone or at a personal 

meeting. Most differences are settled in these 

cases without expensive and time-consuming 

court trials. Appeals will consider any reason you 

have for disagreeing, except for moral, religious, 

political, constitutional, conscientious objection, or 

similar grounds. Our goal is to provide a forum for 

us to work together to resolve the tax dispute. 

You can deal with Appeals by yourself, and 

you may bring a person with you to support 

your position. If you want to be represented by 

someone else, you must choose a person who is 

an attorney, a certified public accountant, or an 

enrolled agent authorized to practice before the 

IRS. If you plan to have your representative talk 

to us without you present, we need a copy of a 

completed power of attorney Form 2848, Power of 

Attorney and Declaration of Representative. 

If you provide significant new information on a 

major issue, we generally ask the examiner for 

their opinion in writing and share their comments 

with you. When there is a need for further 

clarification from the examiner, we may contact or 

invite you to participate in a conference call or a 

meeting with them.