I understand that CDP Appeals and Equivalent Hearings can be done before the tax resolution alternative has been implemented. In that case, is the pricing for the resolution option adjusted somehow to include the appeals?
Eric, when you say that it is potentially malpractice not to request a CDP hearing, are you saying that we should always try to have the CDP hearing before we start on the job of implementing a resolution option?
I can use some clarity on how appeals fits into the work flow of the resolution process.
When you get the case you start working with collections. If the final notice comes out, and it covers all the periods in question, you file the CDP to avoid the levy and continue prepping to deal with appeals, and you work out an arrangement with appeals. If the CDP does not cover all the periods then you have to file the CDP but keep dealing with collections and if collections resolves the issue you can withdraw the appeal when you hear from them. If not or it doesn’t happen in time, then work with appeals and see if they give you the deal you want.