Part 3 Collection question: Collection Due Process hearing with Tax Court review after a levy notice

Part 3Collection

To get a Collection Due Process hearing with Tax Court review after a levy notice, the taxpayer must file Form 12153 within:

A 60 days after the date of the notice
B 30 days after the date of the notice
C 90 days after the date of the notice
D 1 year after the date of the notice

Show the answer and explanation

Answer: B. 30 days after the date of the notice

A timely CDP request must be made within 30 days of the date of the levy notice (for liens, within 30 days after the 5-business-day period following the filing of the notice of federal tax lien). A late request within 1 year gets only an equivalent hearing, with no Tax Court review and no suspension of collection. Source: IRC 6330(a)(3)(B), 6320(a)(3)(B); Treas. Reg. 301.6330-1(i); Form 12153 instructions. Tax year: 2025 (law as of 31 Dec 2025).

Common mistake

Confusing the CDP deadline with the 90-day deficiency period.

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Part 3 Collection question: Collection Due Process hearing with Tax Court review after a levy notice

Answer: B. 30 days after the date of the notice

Common mistake

Related Part 3 practice questions

Part 3 Collection question: Collection Due Process hearing with Tax Court review after a levy notice

Answer: B. 30 days after the date of the notice

Common mistake

Related Part 3 practice questions