Office of Appeals – What will happen when you request a Collection Due Process or an Equivalent hearing? (Part IV)
Appeals will retain jurisdiction over its determination. You may return to Appeals if you believe that the Collection function did not carry out Appeals’ determination as it was stated or if there is a change in your circumstances that affects Appeals’ determination. However, you must first try to work with Collection to resolve the problem.
If your request for a CDP hearing is not timely and you request an equivalent hearing, the law does not prohibit levy and the collection statute is not suspended. Furthermore, you cannot go to court if you disagree with Appeals’ decision.
(IRS Publication 1660) (TTT 04/09/19)