Can the IRS Continue Collections During a CDP Hearing?
A common and critical question taxpayers ask is: Can the IRS continue collections during a Collection Due Process (CDP) hearing?
In most cases, no, temporarily, as long as the CDP hearing was requested on time. A timely CDP request can pause certain IRS enforcement actions while the IRS Office of Appeals independently reviews the case.
Understanding how IRS collections work during a CDP hearing helps you avoid surprises and protect your procedural rights.
What Happens to IRS Collections During a CDP Hearing?
When a CDP hearing is requested within the deadline listed on the IRS notice, the IRS is generally required to pause specific levy actions while the hearing is pending.
During a timely CDP hearing:
- Certain levy actions are typically suspended
- Wage garnishments tied to the notice may be paused
- Bank levies related to the notice are usually delayed
This temporary pause is one of the most important protections provided by a CDP hearing.
Why the IRS Pauses Collections During CDP
CDP hearings exist to ensure procedural fairness. The pause allows Appeals to review whether:
- IRS collection procedures were followed correctly
- The proposed enforcement action is appropriate
- Taxpayer rights were respected
This pause is not permanent, but it provides breathing room during review.
Are All IRS Collections Stopped During CDP?
Not always. While many levy actions are paused, some activity may continue depending on the case.
For example:
- Interest and penalties may continue to accrue
- Collection actions unrelated to the CDP notice may proceed
- Issues outside the scope of the hearing may continue
The exact impact depends on the notice involved and the facts of your account.
CDP Hearing vs. EQ Hearing: Collection Impact
| Hearing Type | Are Collections Paused? | Enforcement Risk |
|---|---|---|
| CDP (Timely) | Often yes | Lower |
| EQ (Late) | No | Higher |
Key takeaway: Timing determines protection.
What Happens When the CDP Hearing Ends?
After the hearing, the IRS Office of Appeals issues a CDP determination. Once issued:
- The temporary pause on collections may end
- The IRS may resume enforcement if authorized
- Future actions depend on the determination and deadlines
FAQs
Does a CDP hearing stop all IRS collections?
No. It usually pauses certain levy actions, not all activity.
What if my CDP request was late?
It may be treated as an EQ hearing, which does not pause collections.
Why is timing so important?
Because only timely CDP requests trigger collection protections.
If you have received an IRS levy notice and believe you have CDP rights, timing matters.
Request a confidential CDP eligibility review today.
Pillar Page: IRS Collections & Appeals
- What Is a CDP Hearing?
- Can the IRS Resume Collections After CDP?
- Bank Levies During a CDP Hearing
- CDP vs. EQ Hearing Explained
This structure strengthens topical authority and improves crawl depth.
Educational Notice
This content is for general educational purposes only and is not legal or tax advice. Outcomes depend on individual facts, timing, and eligibility.