Collection due process and passport certification cases

This lesson is part of the full course.

In it you will learn to:

• Trace a collection due process (CDP) case from the lien or levy notice through the Appeals hearing to a Tax Court petition, with every deadline
• Decide when a taxpayer may challenge the underlying liability, and which standard of review applies to each issue
• Explain when levy is suspended during a CDP case, the exceptions, and the effect of Commissioner v. Zuch (2025)
• Evaluate collection alternatives the Court reviews, including the 24-month deemed-acceptance rule for offers in compromise
• Apply IRC § 7345 and Rules 350 to 354 to a passport certification dispute