Opening paragraph

When you dispute an IRS assessment or collection action, certain administrative requests can temporarily halt enforced collection so you can present your case. Knowing which requests automatically stop collections (and the deadlines to meet) is essential to protect wages, bank accounts, and property.

Quick overview: what pauses collection immediately

  • File a timely Collection Due Process (CDP) request (Form 12153) within 30 days of the IRS notice — a timely CDP generally prevents levy actions while the appeal is pending. (See IRS: Collection Due Process (CDP).)
  • If you aren’t eligible for CDP, request relief through the Collection Appeals Program (CAP) — CAP can provide similar administrative relief in certain cases. (See IRS: Collection Appeals Program.)

Step-by-step: how to stop collections while you appeal

  1. Read the notice and calendar deadlines
  • Most CDP rights begin with a statutory notice (for example, a Notice of Intent to Levy or a Notice of Federal Tax Lien). You typically have 30 days from the notice date to file Form 12153. Miss that deadline and you lose the automatic CDP stay. (IRS CDP guidance.)
  1. File Form 12153 for a CDP hearing
  • Use Form 12153, “Request for a Collection Due Process or Equivalent Hearing.” Submit it to the address on the notice, and keep proof of mailing or delivery. A timely request usually halts levy actions while the Office of Appeals reviews your case. (IRS: About Form 12153.)
  1. Consider CAP if CDP doesn’t apply
  • If the collection action isn’t CDP-eligible (or the CDP window passed), the Collection Appeals Program may still give you an administrative avenue to contest collection actions and request delays. (IRS: Collection Appeals Program.)
  1. Use a Power of Attorney if you want professional representation
  • File Form 2848 to let an attorney, CPA, or enrolled agent represent you; a representative can file appeals and negotiate on your behalf. (FinHelp guide: Using a Power of Attorney (Form 2848) During an Audit or Appeal.)

Other ways to pause collection while you work the case

  • Currently Not Collectible (CNC) status: If you have severe financial hardship, the IRS may mark the account CNC, which suspends collection while the hardship exists.
  • Offer in Compromise (OIC): Submitting a complete OIC can change collection activity while the IRS considers the offer; procedures and eligibility rules apply. (IRS: Offer in Compromise.)
  • Installment agreement: Entering into an agreed payment plan can stop levies while the agreement is in effect.

What an appeal does and doesn’t automatically stop

  • Timely CDP request: generally suspends levies and most enforced collection actions during the appeal. It also lets you request lien withdrawal or challenge the underlying liability.
  • Appeals filed outside CDP procedures or simple administrative protests to the collection function do not always create an automatic stay — you may need CAP or an agreement to pause collection.

Common mistakes that restart collections

  • Missing the 30‑day CDP deadline. If you miss it, you forfeit the statutory CDP stay and often must rely on CAP or litigation (e.g., filing a petition with the Tax Court) to seek relief.
  • Assuming an appeal before the Office of Appeals always stops collection — only certain requests (CDP, certain CAP actions) guarantee a pause.
  • Not documenting submissions and the IRS correspondence address; keep certified mail receipts and copies of all forms.

Practical checklist (what to do now)

  • Immediately identify the IRS notice and the date on it.
  • If within 30 days, complete and mail Form 12153 (keep proof of delivery).
  • If past 30 days, ask about CAP and CNC options and whether an installment agreement or OIC is appropriate.
  • Consider filing Form 2848 to authorize a tax professional to act for you. (FinHelp: Using a Power of Attorney (Form 2848) During an Audit or Appeal.)

When to escalate beyond administrative appeals

If administrative appeals and collection alternatives fail, you may be able to file a petition in U.S. Tax Court after an adverse CDP decision. Discuss timing and strategy with a tax attorney or experienced practitioner — litigation changes the rules and timelines.

Examples from practice

  • A small business client who timely filed Form 12153 stopped an IRS bank levy, allowing 90 days to gather payroll records and negotiate a settlement.
  • Another client missed the CDP window; we requested CAP and negotiated an installment agreement to prevent an imminent levy.

Sources and further reading

Professional disclaimer

This article explains general procedures and deadlines as of 2025 and is for educational purposes only. It does not replace personalized legal or tax advice. For case-specific guidance, consult a qualified tax attorney, CPA, or enrolled agent.