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

Wednesday, September 16, 2026 · 1:00 p.m.  |  Eastern Time (US & Canada) (GMT -4:00)

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Presenters
1787069421-c5f6d92087897679
Nicholas Berger
Nick helps individuals and businesses with a variety of tax-related matters find relief through his efforts as a tax attorney. These include negotiations with the federal and state government agencies to adjust accounts and settle tax matters, criminal investigations, tax planning, and strategy development. His experience working at the Comptroller of Maryland gives him a distinctive outlook on corporate income tax, individual income tax, sales and use tax, withholding tax, and admissions and amusement tax matters.
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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.
About
Program Field of Study: Taxes, Federal Tax Related Matters
Program Level: Basic
Credits: 1 CPE | 1 CE
Advanced Preparation: None
Prerequisite: None
IRS Program Number: JWRXB-T-00025-26-O

This course reviews the procedural rules and strategic considerations governing IRS Collection Due Process and CAP appeals, giving practitioners guidance on choosing the right appeal mechanism and advocating effectively for clients in collection matters.
Agenda
  • Distinguish between Collection Due Process (CDP) 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
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