An IRS Final Notice of Intent to Levy (CP90, LT11, or Letter 1058) starts a 30-day clock. After 30 days, the IRS can levy your bank accounts, garnish your wages, or seize property. The right response within that window is a Collection Due Process (CDP) hearing request.

Here is the actual issue: these notices look procedural and people often set them aside thinking they have more time. They do not. The 30 days is real, and the levy that follows is the difference between owing the IRS money and having no access to your bank account.

Which Notice Did You Get?

The notice that triggers full enforcement is the one titled “Final Notice of Intent to Levy and Notice of Your Right to a Hearing.” That is CP90 (individuals) or LT11/Letter 1058 (businesses and other situations). The 30-day clock to file a Collection Due Process (CDP) hearing request starts on the date of the notice, not the date you received it.

What to File Within 30 Days

File Form 12153 (Request for a Collection Due Process or Equivalent Hearing) within 30 days of the notice date. This stops levy action and gives you a hearing before IRS Appeals before any enforcement can proceed.

Form 12153 is the IRS’s procedural mechanism for stopping a levy. Filing it does several things:

• It stops levy action immediately. The IRS cannot levy while the CDP hearing is pending.
• It moves the case to IRS Appeals. Appeals is independent from Collections and considers settlement alternatives the original collection employee cannot.
• It preserves your right to Tax Court review. If Appeals does not resolve favorably, you can petition Tax Court within 30 days of the determination.
• It runs out the Collection Statute Expiration Date. The CDP process tolls the CSED, so this is a trade-off.

Miss the 30 days and you lose the CDP hearing right. You can still request an Equivalent Hearing within one year, but the Equivalent Hearing does not stop the levy and does not preserve Tax Court rights. Both are useful tools — the CDP is the more powerful one if you can file within the window.

What to Do in Parallel With the CDP Filing

The CDP hearing buys you time. The time has to be used to build the actual resolution:

• Pull your account transcripts on each year involved. Confirm the IRS’s numbers. We frequently find errors that reduce or eliminate the underlying liability.
• File any missing returns. The IRS will not negotiate a resolution while you are out of compliance on filings.
• Run the resolution analysis. Installment agreement, partial-pay installment, Offer in Compromise, or Currently Non-Collectible. The CDP hearing is the forum to present the proposed resolution.

See our tax debt resolution cost page for what each path typically costs.

If You Already Missed the 30-Day Window

Not the end of the world — but the options are narrower. The Equivalent Hearing (also Form 12153) gives you a hearing with IRS Appeals but does not stop a levy and does not preserve Tax Court rights. In parallel, we can negotiate directly with the assigned RO to halt collection action while we propose a resolution. The right move depends on whether a levy has already been issued.

If a levy has been issued — bank account frozen, wages garnished — see our bank levy page and wage garnishment page. Levy release is usually a same-week engagement.