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