There are many instances where an Appeal may be the appropriate action to take. One is under reasonable cause which may abate penalties such as failure to file or failure to pay. This relief may be granted when reasonable care and prudence is given in filing and paying taxes, but due to circumstances beyond your control you were unable to timely file or pay the tax due.
Collection Due Process should be considered when a Notice of Federal Tax Lien and/or a Notice of Intent to Levy has been received and you do not believe that you owe the money, or if either action would create a hardship situation. There is a 30 day time period which is reflected in either of these notices to file a Collection Due Process.
Another appeal option is the Collection Appeals Program if you have received the following Notices; a Notice of Federal Tax Lien; a Notice of Levy; a Notice of Seizure or a Denial or Termination of Installment Agreement, and disagree with these notices and the actions that may be taken.