Background to a Fair Collection Due Process Hearing In a previous Taxing, Briefly article, we discussed the IRS collection process including Collection Due Process (CDP) appeal procedures.  As we noted in that article, a CDP appeal is a taxpayer’s opportunity to dispute the appropriateness of a lien or levy.[1] In this post, we'll discuss the disqualification of an IRS Appeals Officer for prior involvement in a collection due process hearing and the IRS's vehement arguments against such "fairness" in a CDP hearing. When someone fails to pay tax, the IRS will assess the liability against her and send a notice and demand letter.[2] After that, things only get worse for the taxpayer. The taxpayer’s tax liability will become a lien in favor of the IRS against all of its property,[3] and if the taxpayer does nothing, shortly thereafter, the taxpayer will receive a notice of intent to levy (a politely…