Clients of mine, dissatisfied with the ACS process, have occasionally filed a CDP Appeal after they received a Notice of Intent to Levy, but not the FINAL Notice of Intent to Levy. These "premature" CDP Appeals were rejected and the client told no Appealable event (Notice-wise) has occurred.
I have informally told them to simply wait for the NEXT notice which will in fact (probably?) be the FINAL Notice of Intent to Levy. Is there any harm in telling them to sit back and wait for the Final Notice?
For Appeal minded taxpayers I wonder how few/many cases are resolved without an Appeal between the Notice of Intent to Levy and the Final Notice of Intent. Unless I'm missing something I feel it is a huge waste of everyone's time to bounce a "premature" Appeal that late in the case knowing that (I'd guess) 90%+ are eventually refiled anyway a few weeks later.
Any thoughts/ experiences appreciated.