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Form 12153 MS: What You Should Know

When does a Request for a Collection Due Process Hearing Become Reasonable with the IRS? — Solo An agency action (such as a levy or lien) or government decision becomes reasonable and a claim in a collection claim should be filed within the statutory time period if: Is the claimant can demonstrate the claim did not begin activity within 3 years before: The burden is on the taxpayer to bring a CDP claim within 2 years if: It is up to the taxpayer (not the IRS) to request a Hearing/Request for a Hearing, an Equivalent Hearing / Appellate hearing, or a Judicial review of the IRS's action. The burden is on the taxpayer to get a Hearing or Request for Hearing within 4 years from: The IRS or its service provider (e.g., the collector), or the person that requested the collection, is a party to the collection. This time period applies even if the IRS is responsible for the collection.

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