Letters
E-8. Explanation to attach to Form 12153 (Collection Due Process hearing request)
Adapt a model explanation for Form 12153, identify the collection action being appealed and check the notice-specific hearing deadline separately.
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Review status: book guide, pending professional review. This text has not yet been reviewed by an enrolled agent, CPA, or attorney. It is general education, not advice for your situation. Figures, forms, and thresholds change; verify them on IRS.gov.
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The form has a small box. Attach this as a page and write "see attached" in the box.
Attachment to Form 12153, [your name], SSN ending [digits]
Tax periods: [list every period on the notice].
I am requesting a Collection Due Process hearing in response to [Final Notice of Intent to Levy dated [date] / Notice of Federal Tax Lien Filing dated [date]].
Issues I wish to raise:
1. Collection alternative. I am proposing [an installment agreement of $[amount] per month / an offer in compromise / currently not collectible status based on economic hardship]. My financial statement is [enclosed / will be submitted within 14 days].
2. Appropriateness of the collection action. A levy at this time would [prevent me from paying rent and utilities / prevent my business from meeting payroll / other specific consequence]. [If applicable: I was not in receipt of the final notice until [date] because [reason].]
3. [If applicable] Spousal defense. I have [filed / am filing] Form 8857 requesting innocent spouse relief for these periods.
4. [If applicable] Penalties. I request abatement of the [type] penalty for [year] for reasonable cause, as explained in the enclosed letter.
5. [If applicable, and only if you did not receive a notice of deficiency or otherwise have a prior opportunity] Underlying liability. I dispute the assessment for [year] because [reason].
I request that no levy action be taken while this hearing is pending.
[Signature, date]
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