In response to criticisms of the IRS's collection practices, and in an effort to create a more traditional debtor-creditor relationship between the TP and the IRS, Congress created the CDP procedures in 1998. Under these procedures, before the IRS can levy on the property of the taxpayer, it must give the TP the opportunity for review of the IRS's collection actions by the IRS Appeals Division. This presentation examines both steps of the CDP process: (1) administrative review at the Appeals level and judicial review of the Appeals determination. It focuses on how to request CDP consideration, how CDP hearings are conducted by Appeals, and what types of issues the Appeals Officer must consider as part of the hearing. Court review in CDP cases covers the following topics: (1) court jurisdiction over CDP appeals, (2) can a TP voluntarily dismiss a CDP case?, (3) the standard of review in CDP cases, and (4) is review limited to the records of the CDP hearing at the administrative level.

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