IRS Letter 6330: How to Prepare for a Collection Due Process Hearing

Quick overview

IRS Letter 6330 is the formal notice that starts the Collection Due Process (CDP) protections for many collection actions. The letter tells you: what tax period or tax type is at issue, the collection action the IRS intends to take (for example, a levy or filing a Notice of Federal Tax Lien), and the deadline to request a CDP hearing. Requesting a hearing correctly and on time is often the single most important step to stop enforced collection and to present alternatives like an installment agreement or an offer in compromise.

(Authoritative references: IRS — Understanding Your IRS Notice; IRS — Appeals: Collection Due Process.)

Why Letter 6330 matters

• It preserves certain appeal rights: a timely request for a CDP hearing generally prevents the IRS from proceeding with a levy while your hearing is pending and gives you access to the independent Appeals Office.
• It creates an official record: the hearing is your chance to have an Appeals officer review the IRS’s file, the collection action’s appropriateness, and any alternatives.
• It opens negotiation opportunities: Appeals can accept installment agreements, currently not collectible status, or recommend other remedies to resolve collection.

Important: deadlines are strict. You usually have 30 days from the date on Letter 6330 to file Form 12153 (Request for a Collection Due Process or Equivalent Hearing), so act quickly. (IRS: How to Request a CDP Hearing; see Form 12153 guidance.)

Step-by-step: How to request a CDP hearing (practical checklist)

1. Read Letter 6330 carefully — note the date and which action is proposed (levy vs. lien).
2. Complete Form 12153 and sign it. The form is the official request for a CDP hearing; include a daytime phone number and explain briefly why you want a hearing. (IRS Form 12153: Request for a Collection Due Process or Equivalent Hearing.)
3. Mail or fax the form to the address or fax number shown on the letter. Keep proof of mailing or fax confirmation.
4. If you need extra time to gather documentation, send Form 12153 on time and then follow up with documents requested by Appeals.
5. If you miss the 30-day deadline, consider the Collection Appeals Program (CAP) or other post-deadline options, and consult a tax professional promptly — late petitions are not guaranteed to be accepted.

Documents to assemble before your hearing

Bring organized copies — do not send originals unless requested:

• The IRS Letter 6330 itself and any other IRS notices (e.g., Notice of Intent to Levy, Notice of Federal Tax Lien).
• Account transcript or IRS account statements showing assessed taxes, penalties, and payments (you can get these from irs.gov or by requesting your account transcript). (IRS: Get Transcript.)
• A copy of Form 12153 and any correspondence with IRS Collection.
• Proof of income (recent pay stubs), bank statements (2–3 months), copies of your most recent federal tax returns, and a current budget showing monthly income and expenses.
• Completed financial disclosure: Form 433-F (Collection Information Statement) or Form 433-A/B as relevant. Appeals may request one to assess ability to pay. (IRS Forms 433-F and 433-A.)
• Documentation of special circumstances: medical bills, proof of unemployment, mortgage statements, dependent care costs, or other items supporting inability to pay.
• If disputing liability, include any returns, corrected returns, or supporting documentation that shows the tax is incorrect.
• Power of attorney or written authorization if an attorney, CPA, or enrolled agent will represent you (Form 2848). (IRS: Form 2848.)

Tip from my practice: prepare a one-page summary for the Appeals officer that states your request (e.g., installment agreement, currently not collectible, offer in compromise), the reasons, and a short financial snapshot. That helps keep the conversation focused.

Building your case: key arguments and evidence

Common grounds you can raise at a CDP hearing:

• Incorrect amount assessed: provide corrected records, transcripts, or returns that show a lower balance.
• Statute of limitations/collection: if too much time has passed since assessment, you may challenge collection (provide dates and proof).
• Financial hardship: show income, necessary expenses, and why an installment agreement or currently not collectible (CNC) status is appropriate.
• Alternative resolution available: present a feasible installment agreement (direct debit is often favored) or explain why an Offer in Compromise may be appropriate.

Do not assume Appeals will accept an Offer in Compromise automatically — Offers have strict qualification rules and documentation requirements. See our guides on Offers in Compromise for application details and practical examples: Offers in Compromise: How to Settle Your Tax Debt for Less (internal link) and When an Offer in Compromise Makes Sense (internal link).

What to expect during the hearing

• Format: Hearings are typically informal and often conducted by phone, though you can request an in-person meeting in some cases. An Appeals officer (independent of the collector) will review the file and hear your arguments.
• Duration: Most phone hearings last 30–60 minutes, depending on complexity. Have your key documents and summary ready.
• Questions: the officer will ask about your financial situation, the taxpayer’s ability to pay, and any disputes about the tax amount. Expect follow-up requests for documents.
• Representation: you can represent yourself or authorize a representative (attorney, CPA, enrolled agent). If represented, provide Form 2848.

In my experience, being concise and providing a clear remedy request (installment plan with proposed monthly payment, or a realistic Offer in Compromise amount) produces better outcomes than a long narrative.

Common errors to avoid

• Waiting to file Form 12153. Missing the 30-day window forfeits CDP protections in many cases.
• Sending incomplete financial information. Appeals wants enough data to evaluate ability to pay — a half-filled Form 433-F often leads to delays or denial.
• Assuming the hearing is merely a formality. Appeals decisions are binding on the IRS collector in many cases.
• Failing to file required tax returns. Appeals will usually ask for delinquent returns; without them, options like installment agreements or OIC are limited.

After the Appeals decision

• If Appeals grants your request (installment agreement, CNC status, or OIC recommendation), the collector must follow that outcome.
• If Appeals issues a determination you disagree with: you may have limited further remedies. For a CDP involving a filed Notice of Federal Tax Lien, you generally have 30 days from the date of Appeals’ determination to file a petition in U.S. Tax Court challenging the determination. (IRS: Appeals: Collection Due Process.)
• If your hearing related only to a proposed levy and no lien was filed, the right to go to Tax Court may be different — consult a tax attorney or advocate quickly.

Interaction with bankruptcy and other remedies

Filing for bankruptcy affects IRS collection rights and may change the scope of a CDP hearing. Bankruptcy and CDP issues are complex — consult an insolvency practitioner or tax attorney before filing. Alternatives to pursue with Appeals include installment agreements and Offers in Compromise; see our resources for more detail on installment plans and offers in compromise:

• Installment Agreements Explained: Types, Qualifications, and Costs (internal link: https://finhelp.io/glossary/installment-agreements-explained-types-qualifications-and-costs/)
• Offers in Compromise: How to Settle Your Tax Debt for Less (internal link: https://finhelp.io/glossary/offers-in-compromise-how-to-settle-your-tax-debt-for-less/)

Practical timeline example (what to do, week-by-week)

Week 1: Read Letter 6330, note deadline, gather key documents, complete and send Form 12153.
Week 2: Order IRS transcripts, complete Form 433-F, and assemble proof of income and necessary expenses.
Week 3: Draft a one-page summary of requested resolution and supporting evidence; submit additional documents to Appeals as requested.
Week 4–8: Participate in the scheduled Appeals hearing (often by phone). Expect follow-up requests and finalize any agreed repayment arrangement.

FAQs (short answers)

• What if I miss the 30-day deadline? You may still contact the IRS and request an Appeals hearing or use the Collection Appeals Program (CAP), but CDP rights can be lost. Consult a tax professional immediately.
• Will filing Form 12153 stop a levy? Filing timely usually suspends enforced collection (levy) while the CDP hearing is pending, but there are exceptions. (IRS: Collection Due Process.)
• Can I challenge the tax liability at CDP? Yes, but there are limits — if you previously had an opportunity to dispute the liability (for example, through a statutory notice of deficiency), Appeals may not re-open the same liability issues.
• Can I be represented? Yes — use Form 2848 to authorize a representative.

Final professional tips

• Act immediately: missing the Form 12153 deadline is the most common and harmful mistake.
• Be organized: a concise packet and a one-page summary will help the Appeals officer understand your requested remedy quickly.
• Be realistic: offer a reasonable installment amount backed by documentation. If an Offer in Compromise is the right path, follow the program guidance and documentation rules closely.
• Get help when needed: an experienced tax professional (CPA, enrolled agent, or tax attorney) can meaningfully improve outcomes; in my practice, well-prepared representation often converts a potential levy into an affordable installment agreement.

Sources and further reading

• IRS — Understanding Your IRS Notice (general guidance on notices) (https://www.irs.gov/individuals/understanding-your-irs-notice)
• IRS — Appeals: Collection Due Process (CDP) (https://www.irs.gov/appeals/collection-due-process-cdp)
• IRS — Form 12153, Request for a Collection Due Process or Equivalent Hearing (https://www.irs.gov/forms-pubs/about-form-12153)
• IRS — Forms 433-F and 433-A (Collection Information Statements) (https://www.irs.gov/forms-pubs)

Disclaimer: This article is for educational purposes only and does not constitute legal, tax, or financial advice. For guidance that considers your full facts and tax history, consult a qualified tax professional or attorney.