What happens after a CDP hearing — can I go to Tax Court?
A Notice of Determination starts a 30-day window to petition the U.S. Tax Court. The court reviews Appeals for abuse of discretion, and your levy stays suspended while it does.
How long do I have to petition the Tax Court?
After Appeals issues a Notice of Determination, you have 30 days to file a petition with the U.S. Tax Court.
IRC §6330(d)(1)
What standard does the court apply?
Review is generally for abuse of discretion — whether Appeals' determination was arbitrary, capricious, or without sound basis — not a fresh look at the whole case. This is why the record you build at the hearing matters so much.
Is my levy suspended during review?
Yes. The levy remains suspended while the Tax Court review is pending.
What if collection ignores the determination?
Appeals retains jurisdiction after its determination. If Collection does not honor the determination, or circumstances change, you return to Appeals rather than starting over.
IRC §6330(d)(3)