A CP90 is a Final Notice of Intent to Levy with Collection Due Process rights — functionally the same critical letter as an LT11, with the same 30-day clock. The IRS uses different letter numbers depending on which unit issues the notice; the legal effect under IRC § 6330 is identical.
By Sam Brotman, JD, LLM, MBA · Last updated August 2026
Your deadline
30 days from the notice date to file Form 12153 and request a Collection Due Process hearing. Timely filing stops levy action while the case is heard and preserves Tax Court review.
What happens if you ignore it
The IRS gains the legal authority to levy wages, bank accounts, Social Security benefits, and other income sources, and to file the federal tax lien if it has not already. CP90s frequently precede levies on retirees and fixed-income taxpayers — Social Security can be levied at 15% through the Federal Payment Levy Program.
Your options
File the CDP request and negotiate from protected ground: installment agreement, currently-not-collectible status (particularly relevant on fixed incomes), Offer in Compromise, or a challenge to the liability itself if you never had a prior opportunity to dispute it.
What we do
Immediate Form 12153 filing, transcript verification, and a resolution built around your actual ability to pay. For fixed-income clients, currently-not-collectible status is often the honest answer — and it stops enforcement entirely while the collection statute runs.
Holding this notice now? Book a free 15-minute call or call (619) 378-3138. We will tell you exactly where you are in the collection process and what your options are before you spend anything. Our IRS collections attorney team handles these matters statewide.