What is an Equivalent Hearing?
An Equivalent Hearing is the fallback when the 30-day CDP window closes. You still get an Appeals conference, but without the statutory protections a CDP hearing carries.
When is an Equivalent Hearing available?
When you miss the 30-day CDP deadline. For a levy, you can request one within 1 year of the levy notice date. For a lien, within 1 year plus 5 business days after the Notice of Federal Tax Lien filing.
What does an Equivalent Hearing give up?
- No automatic levy suspension. The IRS often holds off in practice but is not required to.
- No CSED tolling. Your collection statute keeps running.
- No Tax Court review. The outcome is a Decision Letter, not a Notice of Determination.
What is the same?
You still get an Appeals conference. Appeals may consider collection alternatives, and in appropriate cases the underlying liability. For many taxpayers it is a real second chance — just without the leverage a timely CDP request provides.