> A face-to-face meeting, > Written or oral communications between the Settlement Officer and the taxpayer or the taxpayer's representative, or > Some combination of meetings and communications > If the taxpayer requests a face-to-face meeting, the IRS ordinarily will offer to conduct the hearing at the Appeals office closest to the taxpayer's residence or principal place of business. If that is not satisfactory to the taxpayer, the IRS will give the taxpayer an opportunity for a hearing by correspondence or by telephone.
5. Effect on Collections 6. Judicial Appeal
Collection activity stayed until IRS Appeals issues determination Yes - The Tax Court's standard of review for non-liability CDP determinations is to consider: •Whether Appeals' factual and legal conclusions reached at a CDP hearing are reasonable, not whether they are correct
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administrative appeal process, taxpayers are not entitled to a faceto-face hearing by statute. >However, there may be situations in which a face-to-face hearing request should be granted to reach account resolution. >These situations will more than likely be rare, but if requested, the employee and their manager should consider the facts and circumstances in making the determination to approve or deny the request. Note: If a face-to-face hearing is not necessary to resolve the account or fully explain Appeals' determination to the taxpayer or representative, the conference should be held by telephone Collection Activity stayed No
Case by Case
No - unless one or more of the following issues are raised: > Spousal relief under IRC 6015 > Abatement of interest under IRC 6404(h) > Timeliness of the request for a CDP hearing