Our business wants to dispute an IRS collection notice. Is calling the revenue officer enough to request a hearing?
A phone call to a revenue officer does not automatically constitute a timely request for a Collection Due Process hearing.
By AE Tax Advisors Team · Updated October 29, 2026
A phone call to a revenue officer does not automatically constitute a timely request for a Collection Due Process hearing. The specific notice, required request and deadline must be followed. Other appeal options can differ if the CDP deadline is missed, so notice classification is essential.
A specific business-owner situation
A company calls about a proposed levy but does not submit the required hearing request. The conversation may not preserve the same review rights as a timely formal filing.
Illustrative example, not a client result.
What to establish before filing
- Identify the notice and stated hearing rights.
- Use the required request form or permitted written procedure.
- Retain proof of timely submission.
Which fact changes the answer?
An equivalent hearing or another collection appeal can have different consequences from a timely CDP request. They should not be treated as interchangeable.
A mistake to avoid
Do not assume ongoing discussions extend a statutory hearing deadline.
Records that support the decision
- Notice and mailing evidence.
- Hearing request.
- Submission and correspondence records.
The decision to document
Have a resolution specialist confirm the procedure promptly and preserve rights while substantive negotiations continue separately.
Tax collection disputes and debt settlement require a tax-resolution specialist. AE focuses on proactive planning, tax preparation, amendments and real estate tax strategy.
Business-owner tax planning and preparation scope · Discuss advisory scope with AE
Related questions
- The IRS released our business tax lien. Is that the same as withdrawing its public notice?
- Our bank received an IRS levy. Does the business have to wait until the funds are sent before seeking relief?
Sources and editorial context
General educational information prepared with AI assistance. No individual professional review is claimed. Apply the relevant tax-year rules to the actual records. Editorial policy · AI disclosure.