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Form 12153 Walkthrough: Every Line of the CDP Hearing Request

By Waleed Akram · Last reviewed: October 23, 2026 · General information only — see our disclaimer

Form 12153, Request for a Collection Due Process or Equivalent Hearing, is the two-page form that converts an IRS final notice into a hearing before IRS Appeals — with levy action prohibited and Tax Court review preserved, if it is filled in and mailed correctly inside the 30-day window. The hearing itself — what Appeals may consider, how the determination works, the court path — lives on our Collection Due Process hearing page. This page owns only the paper: every block of the form, in order, with a worked example and the two errors that quietly destroy taxpayers’ rights every year.

General information, not tax or legal advice. Your notice controls your deadline — the date on the notice, not the date you opened it, starts the 30 days.

The worked example used throughout

Meet “Daniel R.” (fictional; details invented for illustration). Daniel received Letter 1058 (LT11), Final Notice of Intent to Levy and Notice of Your Right to a Hearing, dated March 2, covering Form 1040 tax periods 2021 and 2022, balance $18,400. His 30-day window closes April 1. Every entry below is what Daniel writes.

Before you touch the form: the address rule

Send the completed form to the hearing-request address printed on your CDP notice — for Daniel, the address on his Letter 1058 — and enclose a copy of the notice itself. This is the single most common fatal error: the notice carries two addresses, and the payment address sends your hearing request to a processing center that does not handle Appeals. The form’s instructions are explicit — the request goes to the address shown on the notice of lien filing or levy, not the address where payments go.

Item 1 — Taxpayer information

Enter exactly what the notice shows:

Item 2 — The equivalent-hearing checkbox (read this twice)

Item 2 asks you to check a box if you are requesting an equivalent hearing instead of a CDP hearing. The distinction is everything:

The basis box — lien or levy?

Check the box matching your notice:

The reasons section — the most important box on the form

Here you check every ground that applies and state what you are asking for. The grounds, in the form’s structure:

  1. Issues not raised are generally waived. Appeals decides the case you present; a ground you never mention cannot be raised for the first time in Tax Court. If it might matter, write it now.
  2. Never leave the alternative blank. Appeals cannot grant what you haven’t proposed — this is the second classic fatal error. Even a one-line proposal (“monthly installment agreement; financial statement attached”) gives the hearing something to grant.

Signature — taxpayer OR representative, not both

Sign and date. If a representative signs for you, attach Form 2848 (Power of Attorney) unless one is already on file — an unsigned-by-anyone-recognized form stalls at intake. For joint liabilities, follow the form’s signature instructions for both spouses. Daniel signs himself and dates it March 14 — day 12 of his window.

Mailing — the postmark is your proof

Timeliness is judged by the postmark date, not the date the IRS receives or stamps the form (the timely-mailing rule). Protect it:

No form? A written request still works

Form 12153 is not legally mandatory. Under Reg. §301.6330-1(b), a signed written request is valid if it carries the same essentials: your name and TIN, address and daytime phone, the tax type and periods, a statement that you want a CDP (or equivalent) hearing, your reasons, and your signature and date. The form is still the safer instrument — it prompts for everything — but a deadline-day letter that contains those items preserves your rights; a perfect form mailed a day late does not.

After you mail it

Expect an Appeals conference, typically by telephone. If you proposed a collection alternative, bring what proves it: all returns filed, and a completed Form 433-A (individuals) or 433-B (businesses) with supporting documents. Appeals will verify the IRS followed the required procedures, weigh your raised issues and alternatives, and issue its determination — the hearing’s full mechanics, and the 30 days you then have to petition Tax Court, are covered on the CDP hearing page. If your situation is urgent or the notice is a lien rather than a levy, the faster Collection Appeals Program may fit better. And if the final notice itself is the problem — what LT11/Letter 1058 means and what else it triggers — start with our Letter 1058 response guide. Levy not issued yet? The prevention checklist on how to prevent an IRS levy covers the other statutory bars.

Frequently asked questions

How do I fill out Form 12153? Block by block: your name, TIN, address and daytime phone exactly as the notice shows them; the tax type, form and periods copied from the notice; the Lien or Levy basis box matching your notice; your reasons with the collection alternative you want stated in words; then sign and date. Enclose a copy of the notice and mail it to the hearing-request address on that notice — the walkthrough above works through a complete fictional example.

Where do I send Form 12153? To the address on your Collection Due Process notice (Letter 3172 for a lien, LT11/Letter 1058/CP90 for a levy) — not the payment address printed on the same notice. Timeliness runs from the postmark, so use certified mail with return receipt and keep the stamped proof.

What should I write as my reason for requesting a CDP hearing? Check every ground that applies — a collection alternative, a liability dispute, a procedural defect, a spousal defense — and then state the alternative you are asking for (installment agreement, offer in compromise, currently-not-collectible) with any supporting financial statement attached. Issues you do not raise are generally waived later, so completeness here matters more than polish.

Is Form 12153 required to request a CDP hearing? No. A signed written request containing the same items — name and TIN, address and phone, tax type and periods, a statement requesting the hearing, your reasons, signature and date — is valid under Reg. §301.6330-1(b). The form is recommended because it prompts for each element, but content and timeliness are what the law tests.


General information, not tax or legal advice. Sources: Form 12153 and its instructions (current revision); IRC §§6320/6330; Reg. §301.6330-1(b); IRS CDP FAQs and CDP Deskbook (timely-mailing and written-request rules). Currency verified 2026-10-23.

How we work: every guide is researched against IRS, CFPB, CMS and SBA primary sources, written by Waleed Akram, and date-stamped at review. General information only — not tax, legal, or financial advice. See our editorial policy.