AICPA Comment Letter to Extend CDP Hearing Deadlines

The AICPA recommends extending the 30-day period to request a collection due process (CDP) hearing and to petition the Tax Court for review of a CDP notice of determination to a 60-day period generally and a 90-day period for taxpayers residing outside the U.S. Currently, the Code requires that taxpayers request a CDP hearing within 30 days from the date that the IRS files a notice of federal tax lien or a notice of intent to levy. This 30-day period does not afford taxpayers sufficient time to timely request a CDP, especially when factoring in domestic and foreign mail delays, the complexity of these matters, and the severe consequences associated with placing a lien on or levying taxpayer property.