Check the notice and records
We check the response date, tax periods and balance, including whether a final notice with hearing rights has also been issued.
CP504 warns of intended collection and gives you a date to pay or respond while you review the available options.
Count from the date printed on the notice, not the day it reached you. Pay or respond by the date the notice shows.
CP504 is a notice of intent to levy that can reach a state tax refund. The final notice with hearing rights, Letter LT11 or Letter 1058, normally comes before a levy on wages or bank accounts.
We check the response date, tax periods and balance, including whether a final notice with hearing rights has also been issued.
We assess payment, a payment arrangement, hardship documentation or an appeal using your records.
We prepare the appropriate request and respond to IRS questions; the IRS decides any collection alternative.
CP504 is issued under IRC §6331(d), the general 30-day pre-levy notice provision. It is different from the final notice under IRC §6330 that provides Collection Due Process (CDP) hearing rights. A levy takes property to pay tax; CP504 alone normally does not complete the hearing-rights notice required before a wage or bank levy.
CP504 is for individual income tax balances; CP504B is for business balances such as employment, corporate income or excise tax. The earlier page's example was a notice dated October 1 and received October 17: 16 of 30 days had passed, leaving 14 days to October 31. This illustrates why the printed date matters; use the actual response date on your notice.
The earlier 5-10-week estimate between CP504 and Letter LT11 is not a schedule or a promise. Check whether a final notice was already issued rather than assume another notice will arrive first.
Outside applicable exceptions, levies on wages under IRC §6331(e), bank accounts through Form 668-A, investment or retirement accounts, and tangible property normally require the final notice and hearing opportunity. Prior notices and the type of levy determine the rules in your case.
The State Income Tax Levy Program (SITLP) connects the IRS with participating state revenue departments. Under IRM 5.19.9, the IRS supplies a weekly file of delinquent taxpayers. A participating state may send an affected refund to the IRS instead of the taxpayer.
After that levy, CP92 provides post-levy hearing rights, including a 30-day window for Form 12153. A request to return funds is a separate process and is not guaranteed. Reviewing the balance and available arrangements before that point may provide more options.
The Collection Appeals Program (CAP) is an administrative review of collection action, using Form 9423 under IRM 8.24.1. CP504 itself does not provide the CDP hearing rights that come with Letter LT11 or Letter 1058. CAP decisions do not provide Tax Court review.
A Collection manager conference is required before the CAP request. The existing filing guidance is 3-4 business days after that conference for Form 9423 to be received or postmarked. Confirm the instructions for your action rather than wait until that period ends.
| Factor | CAP — Form 9423 | CDP — Form 12153 |
|---|---|---|
| Authority | Administrative — IRM 8.24.1 | Statutory — IRC §6330 |
| Trigger | CP504, installment agreement rejection, lien filing or levy action | Letter LT11, Letter 1058 or Letter 3172 |
| Filing window | 3-4 business days after the manager conference | 30 days from the date printed on the notice, not the date received |
| Tax Court review | None | Available under IRC §6330(d)(1) |
| Existing timing estimates | 1-4 weeks; not guaranteed | 3-12 months; not guaranteed |
| Scope | Collection action | Collection alternatives and, where eligible, the underlying tax |
A timely CDP request generally pauses levy for the periods covered, with statutory exceptions. It does not guarantee release of an existing levy or acceptance of an alternative. Appeals timing depends on the records and case.
Payment in full addresses the listed liability; confirm the current payoff, correct tax periods and IRS posting rather than assume every collection action has ended. Payment methods include IRS Direct Pay, the Electronic Federal Tax Payment System (EFTPS), debit card and credit card. Keep the confirmation.
An installment agreement under IRC §6159 spreads payments over time. The existing streamlined examples under IRM 5.14.5 are $50,000 or less for individuals and $25,000 or less for in-business taxpayers with required returns filed. Eligibility and the need for a financial statement must be checked.
IRC §6331(k)(2) generally restricts levy during a qualifying pending or active installment agreement, subject to exceptions. Approval and any release of an existing levy must be confirmed separately.
Currently not collectible (CNC) status under IRM 5.16.1 means the IRS finds no present ability to pay after reasonable living expenses. IRS Allowable Living Expense standards guide the review, supported by Form 433-A or Form 433-F. Active enforcement may pause, but refunds may still be offset and a lien may be filed.
The collection statute expiration date (CSED) is the deadline for IRS collection and generally continues running during this status. The existing 3-4-years-before-expiration example calls for a case-specific review, not a promised result.
An offer in compromise under IRC §7122 asks the IRS to accept less than the full balance. Reasonable Collection Potential estimates what the IRS could collect from assets and future income. Form 656 and Form 433-A(OIC) support an offer based on inability to pay.
The existing application fee is $205, with 20% of a lump-sum offer or the first proposed periodic payment. Low-income certification can waive the fee and required payments. The IRS decides whether to accept.
IRC §6331(k)(1) generally restricts levy while an offer is pending, with exceptions; submitting an offer does not itself release an existing levy. IRC §6331(k)(3) affects the collection deadline while pending, for 30 days after rejection and during any appeal. The existing 6–12-month review estimate is not guaranteed.
Letter 3172 concerns a Notice of Federal Tax Lien, separate from CP504. IRC §6321 creates the underlying tax lien, and filing under IRC §6323 protects the government's claim against third parties. Letter 3172 provides a separate 30-day hearing window under IRC §6320 using Form 12153.
Treas. Reg. §301.6330-1(b)(2) addresses combining related hearings. Form 2848 is the power of attorney for IRS representation; Form 9465 requests an installment agreement.
The FAST Act of 2015, Pub. L. 114-94, §32101, created the passport certification framework in IRC §7345. The existing $62,000 figure is the 2025 threshold, adjusted annually, not a current-year eligibility determination. CP508C is a separate certification notice; the State Department may deny or revoke a passport under the applicable rules.
Qualifying resolution through an installment agreement, offer or currently not collectible status can lead to decertification under IRC §7345(c). Erroneous certification may be challenged in Tax Court or U.S. District Court under IRC §7345(e). Tax Court–admitted counsel handles any Tax Court representation.
Ebot Mbi, CPA, EA · Texas CPA #127163 · IRS Enrolled Agent · 4425 W Airport Fwy, Ste 595, Irving, TX 75062.
The scope and fee are confirmed in writing before IRS contact.
Case Analysis is $497 regardless of balance owed, tax years, complexity or urgency. The $97 Notice Review is credited toward the $497 Case Analysis. Phase 2 work is priced in the published ranges on our IRS fee page, or quoted in writing after the Case Analysis. Fixed fees, confirmed in writing before work begins. Not a guarantee of any IRS outcome. We never charge a percentage of tax saved.
Free — Free Notice Decoder / free path. The free decoder explains your notice from its type and date. No documents are uploaded at the free step. $97 — Notice Review. Send us your IRS notice along with your own transcripts. We tell you what the notice is, what it means, and what the issues appear to be at a high level. This is information, not tax advice. $497 — Case Analysis. We pull your transcripts, analyze your whole situation, and give you a written do-it-yourself plan. $1,000 — Representation. Power of attorney (Form 2848) and we represent you before the IRS. Flat $1,000. The $97 Notice Review is credited toward the $497 Case Analysis. Fixed fees, confirmed in writing before work begins. Not a guarantee of any IRS outcome. We never charge a percentage of tax saved.
The engagement letter is the controlling document; no specific outcome or timeline is guaranteed. Texas CPAs are bound by the rules of the Texas State Board of Public Accountancy.
No.
CP504 is the IRC §6331(d) Notice of Intent to Levy — but it does not provide full Collection Due Process hearing rights under IRC §6330 required before wage levy, bank levy, or general property seizure.
After CP504, the IRS may levy your state tax refund through SITLP and may issue Disqualified Employment Tax Levies and Federal Contractor Levies.
Before the IRS can levy wages or bank accounts, it must separately issue Letter 1058 or LT11 — the Final Notice that triggers full §6330 CDP rights.
If you are a resident of a state participating in the State Income Tax Levy Program (SITLP), your state refund may be diverted to the IRS.
After SITLP levy occurs, the IRS sends CP92 (post-levy CDP notice) — a 30-day window to file Form 12153.
Recovery is possible through CDP hearing or wrongful-levy claim under IRC §6343(b), but procedurally weaker than preventing the SITLP levy at the CP504 stage.
Yes — through the Collection Appeals Program (CAP), not CDP.
CAP is filed using Form 9423 per IRM 8.24.1.
Procedural sequence: (1) Request a conference with the Collection manager — mandatory; (2) If unresolved, file Form 9423 within 3-4 business days of the manager conference; (3) Appeals reviews and issues a determination.
CAP determinations are not subject to Tax Court review.
CP504 is issued to individual taxpayers with balance-due income tax liabilities.
CP504B is issued to business taxpayers with employment tax, corporate income tax, or excise tax liabilities.
Both are issued under IRC §6331(d) and serve the same procedural function and legal authority. 30 days from the date printed on the notice — not the day it reached you.
Pay or respond by the date on the notice.
CP504 (§6331(d) levy notice) and Letter 3172 (Notice of Federal Tax Lien Filing under §6320) are independent IRS actions.
The lien attaches automatically when tax is assessed; the NFTL is filed under IRC §6323 to perfect the lien against third parties.
Letter 3172 triggers §6320 CDP rights with a 30-day window to file Form 12153 on the lien filing — separate from the upcoming levy CDP (LT11).
Possibly — through the FAST Act framework (Pub.
L. 114-94, §32101), codified at IRC §7345.
The IRS must certify 'seriously delinquent tax debt' exceeding $62,000 (2025 threshold) to the U.S.
State Department, which may deny or revoke passports.
Certification requires a separate Notice CP508C.
Resolution of the underlying tax debt through IA, OIC, or CNC generally triggers decertification under IRC §7345(c).
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