Webinar: Hold That Levy: Collection Due Process Fundamentals (Part 1) by ALFi

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Presenters

Rebecca Sheppard

Rebecca Sheppard is a Partner at Frost Law with extensive experience representing clients before the IRS and state taxing authorities. She advises on audits, appeals, and tax litigation, focusing on employment tax and the Employee Retention Credit. Rebecca is known for her practical, innovative approach to controversy work and her ability to translate complex tax issues into actionable guidance for practitioners. She regularly speaks on tax procedure and controversy topics to professional audiences. She is a member of the Maryland State Bar Association’s Taxation Section Council.

Peter Haukebo

Peter Haukebo is a tax controversy attorney and Partner at Frost Law, where he represents clients in complex federal and state tax disputes. His practice includes handling IRS audits, appeals, and litigation with a particular focus on employment tax controversies and the Employee Retention Credit. Peter frequently presents to national audiences on tax procedure and controversy topics, blending technical insights with practical strategies. He is admitted to practice in Arizona and Maryland and before the United States Tax Court, Court of Federal Claims, Court of International Trade, and several District Courts. Peter previously taught in the Low Income Taxpayer Clinic at the University of Maryland School of Law and chaired the Taxation Section of the Maryland State Bar Association.

About

Program Field of Study: Taxes, Federal Tax Related Matters
Program Level: Basic
Who Should Attend: Attorneys, Enrolled Agents, CPAs, Small Business Owners
Credits: 1 CPE | 1 CE
Advanced Preparation: None
Prerequisite: None
IRS Program Number: TBA

This session covers the origins of Collection Due Process in the 1998 Restructuring and Reform Act, the notices that start the clock, and what the Internal Revenue Manual and Treasury Manual direct Appeals to do once a request arrives. Attendees will learn what a timely request does and does not stop, and how the collection statute expiration date is suspended while a timely appeal is pending. The session also distinguishes the CDP hearing from the equivalent hearing and from the Collection Appeals Program, and walks through Forms 12153 and 12256 along with the consequences of withdrawal.

Agenda

Identify the notices that trigger CDP rights and calculate the deadline for a timely request
Explain what effect a CDP request has on lien filing, levy action, and the collection statute expiration date
Distinguish a CDP hearing from an equivalent hearing and from a CAP appeal, including the outcome document each produces
Recognize the section 6330(f) exceptions that permit levy before a hearing
Evaluate when withdrawing a request on Form 12256 serves the client and when it forfeits critical rights