Recently, a change to the Internal Revenue Manual (“IRM”) makes clear that in order for a Collection Due Process (“CDP”) Hearing request to be timely, it must show a post-mark date on or before the stated CDP due date (if requested by mail – the request may also be send through fax). Previously, the IRM determined timeliness by when the CDP Hearing Request was “received” by the proper IRS Office. However, requesting CDP review (and the Taxpayer rights associated with it) was often confusing. An IRS Letter routinely has several different addresses: 1 to submit payment, 2 to submit general correspondence and 3 to request a CDP Hearing. Each year, the IRS routinely receives CDP Hearing Requests to the wrong IRS offices and then Fed Exes those Requests to the correct IRS office – leading to delays in receipt by the correct IRS office. That resulted in Taxpayers often losing critical CDP Taxpayer Rights. However, now, under IRM 5.1.9.3.2, Request for CDP Hearing Rights, “… timeliness should be determined by the postmark, meter or fax date of the request, not the date actually received by the office listed on the CDP hearing notice.” This is a welcomed favorable Taxpayer rule.