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IRM Interim Guidance: Determining Timeliness of CDP Hearing Requests When Multiple IRS Addresses Provided (IRC §7502)

June 29, 2020, 5:00 AM

Revision to Internal Revenue Manual 8.22.5 that would provide Appeals officers clarification of CDP timeliness determinations resulting from certain SB/SE lien and levy notices that list more than one IRS address for responding, release June 29. The update is in response to PMTA-2020-02, dated December 12, 2019, that clarified that a request for a CDP hearing should be determined to be timely, based on the postmark date, if sent to any IRS address appearing on a CDP lien or levy notice. The guidance states that if a taxpayer mistakenly sends a timely hearing request to a different address on the...

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