Collection Due Process and Equivalent Hearings

Categories: IRS CE, IRS Resolution
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About Course

This two-hour continuing education course provides tax professionals with an in-depth examination of Collection Due Process and Equivalent Hearings, expanding on the introductory treatment of CDP procedures under IRC Sections 6320 and 6330 found in the broader IRS Collections course elsewhere in this catalog. Where that course introduces CDP as one of several collection procedures, this course builds the complete framework a practitioner needs to actually prepare, file, and litigate a CDP matter from the original notice through Tax Court review.

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What Will You Learn?

  • Distinguish the lien-based CDP rights under IRC Section 6320 from the levy-based CDP rights under IRC Section 6330, and apply the applicable notice and filing deadlines
  • Identify the four statutory exceptions to the pre-levy CDP notice requirement and their post-levy hearing consequence
  • Identify the collection alternatives, spousal defenses, and underlying-liability challenges available at a CDP hearing under Section 6330(c)(2)(B)
  • Explain the consequence of raising a frivolous position and the IRS's own verification obligation under Section 6330(c)(1)
  • Apply the ex parte communication restrictions established under RRA98 Section 1001(a) to preserve Appeals's independence in a CDP matter
  • Explain the function of the Notice of Determination and distinguish it from the Decision Letter issued after an Equivalent Hearing
  • Apply IRC Section 6330(d)(1) to identify the court with jurisdiction over judicial review of a CDP determination and the applicable filing deadline
  • Apply practical strategy to avoid the most common errors in CDP hearing practice

Course Content

Module 1 – The Two CDP Statutes — Notice, Timing, and Exceptions to Pre-Levy Hearing Rights
<p>The Two CDP Statutes — Notice, Timing, and Exceptions to Pre-Levy Hearing Rights</p>

  • The Two CDP Statutes — Notice, Timing, and Exceptions to Pre-Levy Hearing Rights

Module 2 – What Can Be Raised at the Hearing — Collection Alternatives, Spousal Defenses, and the Underlying Liability
<p>What Can Be Raised at the Hearing — Collection Alternatives, Spousal Defenses, and the Underlying Liability</p>

Module 3 – The Independent Office of Appeals — Ex Parte Rules and the Notice of Determination
<p>The Independent Office of Appeals — Ex Parte Rules and the Notice of Determination</p>

Module 4 – Equivalent Hearings, Judicial Review, and Practical CDP Strategy
<p>Equivalent Hearings, Judicial Review, and Practical CDP Strategy</p>

Final Assessment – Collection Due Process and Equivalent Hearings
This final assessment consists of 10 multiple-choice questions covering all four modules of this course. A passing score of 70% or better is required.

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