The IRS makes mistakes — denied Offers in Compromise, rejected penalty abatement, improper liens, and wrongful levies. You have the right to appeal. Dream Financial Management represents taxpayers before the IRS Office of Appeals nationwide since 1994.
After receiving a Final Notice of Intent to Levy (LT11/CP90) or Notice of Federal Tax Lien (LT3172), you have 30 days to request a CDP hearing. This pauses collection while you present your case to an independent Appeals Officer. You can challenge: the amount owed, the appropriateness of collection action, and propose collection alternatives. 30-day deadline is strict — miss it and you lose this right.
File a CAP appeal when the IRS takes or threatens specific collection actions you disagree with — such as a levy, seizure, or rejection of an installment agreement. Faster than CDP but with fewer protections. No judicial review if you lose.
If you miss the 30-day CDP deadline, you can request an Equivalent Hearing within 1 year of the lien/levy notice. You still get an Appeals Officer review — but collection can continue during the hearing and you cannot go to Tax Court if you lose.
Denied OIC? You have 30 days to appeal using Form 13711. Denied penalty abatement? You can request an Appeals conference. Both go to the IRS Independent Office of Appeals for a fresh review by a different officer.
Appeals Officers are independent — their job is to resolve cases fairly, not to maximize collection. This is your chance to get a fresh review from someone who was not involved in the original decision. We prepare your case and represent you through every stage.
Start My Appeal — Free ConsultationCDP hearing requests must be filed within 30 days of receiving your notice. OIC appeals within 30 days of denial. Every day you wait risks losing your right to appeal. Dream Financial Management files appeals nationwide. Free consultation. Since 1994.
Disclaimer: Dream Financial Management provides tax resolution consulting. Appeal outcomes depend on individual case facts. For legal representation before the IRS, consult a licensed tax attorney. Information current as of August 2026.