Ezel / IRS Rulings / 201223018

CCA 201223018: IRS identifies the form for waiving a CDP hearing

Number
201223018
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Collection Due Process - Levy
Topics
Procedure, penalties, and administration
Code sections
§ 6330, § 6110
Ruling dated
May 15, 2012
Publicly released
June 8, 2012
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2012, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2012
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel advice identifies Form 13207 as the form for waiving the right to receive a Collection Due Process hearing under IRC § 6330. The advice also points to the Internal Revenue Manual section describing the form's use for waiving the notice of intent to levy and notice of a right to a hearing.

Ruling snapshot

  • Question: Which form is used to waive the right to receive a Collection Due Process hearing?
  • Outcome: Advice given, identifying Form 13207 and the related Internal Revenue Manual guidance.
  • Key authorities: IRC § 6330; IRM 5.11.1.2.2.10

Full text (IRS public release)

ID: CCA_2012051517434026 Number: 201223018
Release Date: 6/8/2012
Office: --------------
UILC: 6330.00-00

From: -----------------
Sent: Tuesday, May 15, 2012 5:43:41 PM
To: -------------------------
Cc:
Subject: FW: CDP Question from an RO

Hi ---------- The form for waiver of 1058 time is Form 13207, Waiver of Right to Receive a Collection Due
Process Hearing Under Internal Revenue Code (IRC) Section 6330 (1-2002). The use of the form is
described at IRM 5.11.1.2.2.10 (07-26-2002) Waiver of Notice of Intent to Levy/Notice of a Right to a
Hearing.

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