Navigating IRS Appeals: Collection Due Process (CDP), Collection Appeals Program (CAP) Procedures & Practice Strategy

This session examines the procedural framework behind IRS Collection Due Process (CDP) and the Collection Appeals Program (CAP), equipping practitioners with the strategic insight to select the appropriate appeal route and represent clients through collection proceedings.

Agenda:

• Distinguish between Collection Due Process and CAP appeal rights, including eligibility, deadlines, and the scope of issues each allows
• Evaluate the strategic tradeoffs between CDP and CAP procedures, particularly the availability of Tax Court review under CDP versus the speed of CAP
• Apply this knowledge to advise clients and advocate effectively at IRS collection hearings