Office of Appeals – What will happen when you request a Collection Due Process or an Equivalent hearing? (Part III)
At the conclusion of the CDP hearing, Appeals will issue a determination letter unless you have withdrawn your hearing request. If you don’t agree with Appeals’ determination, you may request judicial review of the determination by petitioning the United States Tax Court within the time period provided for in the Appeals’ determination letter. You may not be able to raise issues in the Tax Court if you do not raise them during the Appeals hearing, and the Tax Court may limit the evidence you can present to the evidence you submitted to Appeals during the hearing. You should, therefore, raise all issues and present all evidence during the Appeals hearing, in order to preserve your rights to raise issues and have evidence considered in subsequent court proceedings.
Next week the Tuesday Tax Tip will continue the Appeal process.
(IRS Publication 1660) (TTT 04/02/19)