Date: June 18th, 2026

Time: 2pm ET | 1pm CT | 12pm MT | 11am PT

Duration: 120 Minutes

Course Overview:

When the IRS shifts from assessment to enforcement, the clock starts ticking  and every decision made in those critical early days can define the outcome for your client. A levy notice arrives. A bank account is at risk. A lien has been filed. In these high-stakes moments, tax practitioners need more than general knowledge  they need a precise, battle-tested strategy. The Collection Due Process (CDP) and Collection Appeal Program (CAP) are two of the most powerful protective mechanisms available under the Internal Revenue Code, yet they remain among the most misunderstood and underutilized tools in a practitioner’s arsenal.

Understanding the difference between CDP and CAP is not merely an academic exercise  it is a practical necessity. Each process carries distinct eligibility rules, filing deadlines, procedural pathways, and strategic implications. A practitioner who files the wrong appeal, misses a statutory deadline, or overlooks a procedural requirement can inadvertently forfeit a client’s rights sometimes permanently. On the other hand, a practitioner who knows exactly how and when to invoke these protections can stop enforced collection, buy critical time to negotiate, and steer clients toward lasting resolution.

This session delivers a comprehensive, practitioner-focused deep dive into both the CDP and CAP frameworks. Starting with the foundational mechanics of the IRS Collection function and the Independent Office of Appeals, the course walks through each stage of the appeals process  from the moment a collection notice is issued to the final resolution at the Appeals level. You will gain a clear understanding of how these two processes differ in scope, how each affects ongoing collection enforcement, and what strategic factors should drive your choice between them.

Beyond the procedural framework, this session equips you with actionable, real-world techniques. You will learn how to properly complete and submit Form 12153, the Request for Collection Due Process or Equivalent Hearing, with precision — ensuring full statutory compliance and maximum protection for your client. You will explore how the IRS Reform and Restructuring Act of 1998 created an important avenue for resolving disputes at the supervisor level before formal appeals even begin. And you will gain a firm grasp of the “one-appeal-per-tax-period” rule  a critical limitation that can catch even experienced practitioners off guard.

Whether you are a CPA, Enrolled Agent, or tax attorney regularly handling collection matters, or a practitioner who wants to expand your IRS representation capabilities, this session provides the structured framework, strategic insight, and practical tools you need to confidently protect clients when the IRS comes knocking.

Major Topics Covered

• CAP vs. CDP: A comparative analysis of eligibility, procedural timelines, and the impact of each on collection enforcement.
• Form 12153 Mastery: Best practices for filing the Request for Collection Due Process or Equivalent Hearing to ensure maximum client protection.
• The Supervisor Conference: Leveraging the IRS Reform and Restructuring Act of 1998 to resolve disputes at the management level.
• Strategic Enforcement Stops: Understanding how a properly filed CDP stops collection actions and the nuances of the “one-appeal-per-tax-period” rule.
• The Practitioner’s Playbook: Essential “do’s and don’ts” for preparing successful hearing requests and navigating the appeals lifecycle.

Learning Objectives

• Explain the operational mechanics of the IRS Collection Appeals process.
• Differentiate clearly between the scope and application of CAP and CDP appeals.
• Determine client eligibility for specific appeals based on the type of collection notice received.
  Execute the proper procedure for filing Form 12153 to ensure statutory compliance.
• Apply strategic decision-making to choose the most effective resolution path for specific collection scenarios.

Credits and Other information:

• Recommended CPE credit – 2.0
• Recommended field of study – Taxes
• Session Prerequisites and preparation: None
• Session learning level: Basic
• Location: Virtual/Online
• Delivery method: Group Internet Based
• Attendance Requirement:  Yes
• Session Duration: 120 minutes

Who Will Benefit:

• CPA
• Enrolled Agents (EAs)
• Tax Professionals
• Attorneys
• Other Tax Preparers
• Finance professionals
• Financial planners

About Our Speaker

Marc J. Dombrowski, EA

Marc is one of the most respected voices in IRS collection representation in the country, specializing in IRS and state collection cases, tax lien releases, installment agreements, offers in compromise, and Corporate Officer Assessments. He earned his Enrolled Agent designation in 1994 and is licensed to practice before the IRS in all 50 states. A graduate of Buffalo State University with a BS in Business Studies and Criminal Justice, Marc began his career with Equity Search, Inc. before founding Tax Help Associates in 2000. He has lectured on advanced IRS collection topics since 1994 and is a Level I, Level II, Level III, and Graduate Level instructor with the prestigious National Tax Practice Institute (NTPI). A nationally recognized speaker, Marc has addressed state EA societies across the country, including New York, California, Florida, New Jersey, Tennessee, Michigan, Georgia, Arizona, Washington, Louisiana, Utah, Missouri, and Ohio, as well as NATP conventions.