IRS Collection Due Process Procedures (Video) (Course Id 2678)

Due process is, according to Black’s Law Dictionary, “a course of legal proceedings … which have been established … for the enforcement and protection of private rights.” Anyone facing an IRS federal tax lien or levy has already experienced the preliminary due process following the IRS determination that more taxes are owed.

Due process involves a series of written or telephone notifications, and it’s all laid out in the tax code and the IRS letters the taxpayer receives in the mail that should definitely not be ignored.
Before the IRS wrecking ball goes into motion, the taxpayer has certain procedural rights. In this presentation, I will discuss them in detail.

Course Learning Objectives

1. What are the implications of the Tax Court's decision to not look behind the notice of determination in CDP cases regarding the judicial review process?
2. How does the requirement for a face-to-face hearing impact the taxpayer's experience during the CDP process?
3. In what ways does the suspension of collection actions during a CDP hearing influence taxpayer compliance and behavior?
4. What alternatives do taxpayers have if they miss the 30-day deadline to request a CDP hearing, and how do these alternatives affect their rights?
5. How does the concept of retained jurisdiction by the Appeals Office affect the statute of limitations on tax collection actions?
6. Discuss the potential consequences for taxpayers who raise frivolous arguments during the CDP process. How do penalties serve as a deterrent?
7. How does the judicial review process differ between CDP hearings and traditional tax deficiency cases?
8. What considerations should taxpayers keep in mind when challenging the IRS's proposed collection actions during a CDP hearing?
9. How does the requirement for the Appeals Officer to verify the validity of tax assessments impact the fairness of the CDP process?
10. In what ways can the outcomes of CDP hearings influence taxpayers’ future interactions with the IRS?
11. What role does the notice of determination play in the taxpayer's ability to seek judicial review, and what are the implications of that role?
12. How might the differences in standard of review between tax liabilities and collection activities affect the outcomes of appeals in CDP cases?