You received CP504. Here's what it actually does — and what it doesn't.
CP504 is the IRC §6331(d) Notice of Intent to Levy — required before any IRS levy. But it is not the §6330 Final Notice that triggers full CDP hearing rights. 30 days from the date printed on the notice — not the day it reached you. Pay or respond by the date on the notice. The IRS may then levy your state tax refund through the State Income Tax Levy Program (SITLP). The IRS may not yet levy wages, bank accounts, or general property — those require a separate LT11 / Letter 1058. The right move is to resolve the balance before the IRS escalates to LT11.
Example: a notice dated October 1 that arrives October 17 has already used 16 of its 30 days; the clock ends October 31, leaving 14 days.
Ebot Mbi, CPA, EA · Texas CPA #127163 · IRS Enrolled Agent, federally licensed by the U.S. Department of the Treasury to practice before the IRS · 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. $150 per tax year — Transcript Pull. Don't have your transcripts, or can't get them? We pull them for you under Form 8821 and send them with written findings. Many clients use their transcripts to bring their filings up to date with their own tax preparer. $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. The $150 Transcript Pull is a separate service and is not credited. Fixed fees, confirmed in writing before work begins. Not a guarantee of any IRS outcome. We never charge a percentage of tax saved.
Authority
IRC §6331(d) · IRC §6331(a) · IRM 5.19.9 · IRM 8.24.1
Forms Filed
Form 9423 (CAP) · Form 433-A · Form 2848 · Form 9465
Outcome Targeted
Payment plan · CAP appeal · pre-LT11 resolution
CP504 is not your final levy notice. That comes next.
CP504 satisfies the §6331(d) 30-day pre-levy notice requirement — but the IRS still must issue a separate §6330 CDP notice (LT11 or Letter 1058) before levying wages, bank accounts, or general property. The right move at CP504 is to resolve the balance before the IRS escalates to LT11. Once LT11 arrives, you're in a more aggressive procedural posture with full CDP timing pressure.
Procedural meaning — what the IRS just sent you
CP504 is the §6331(d) notice. Not the §6330 notice.
CP504 is the IRS's Notice of Intent to Levy issued under IRC §6331(d). The statute requires the IRS to provide written notice at least 30 days before any levy action, describing the IRS's levy rules, appeal rights, alternatives, and collection procedures in "simple and nontechnical terms." CP504 satisfies this requirement — but it does not simultaneously provide the full Collection Due Process hearing rights under IRC §6330.
After CP504 — IRS MAY levy:
- →State tax refunds (SITLP) under IRC §6331(a)
- →Disqualified Employment Tax Levies under IRC §6330(h)
- →Federal Contractor Levies under IRC §6330(f)(3)
- →Certain federal payments via FPLP under IRC §6331(h)
After CP504 — IRS may NOT yet levy:
- Wages under IRC §6331(e) — requires LT11 first
- Bank accounts via Form 668-A — requires LT11 first
- Investment or retirement accounts — requires LT11
- Tangible personal or real property — requires LT11
SITLP — what CP504 actually authorizes
State refund levy is the operative threat after CP504.
The State Income Tax Levy Program (SITLP) is an automated levy program administered jointly by the IRS and participating state revenue departments. Under SITLP per IRM 5.19.9, the IRS provides participating states with a weekly file of taxpayers with delinquent federal tax liabilities. When the state processes a refund for a SITLP-listed taxpayer, the state diverts the refund to the IRS rather than issuing it to the taxpayer.
After SITLP levy occurs, the IRS sends CP92 (Notice of Levy upon Your State Tax Refund and Notice of Your Right to a Hearing) — a post-levy CDP notice providing 30 days to file Form 12153. Recovery at that point is procedurally weaker than preventing the levy at the CP504 stage. The strategic incentive is to resolve the underlying liability at CP504 before SITLP levy occurs.
Collection Appeals Program — the available appeal at CP504
CAP is faster than CDP. But narrower.
Because CP504 is a §6331(d) notice and not a §6330 CDP notice, the available appeal is the Collection Appeals Program (CAP) rather than CDP. CAP is filed using Form 9423 (Collection Appeal Request) under IRM 8.24.1.
| Factor | CAP (Form 9423) | CDP (Form 12153) |
|---|---|---|
| Statutory authority | Administrative — IRM 8.24.1 | Statutory — IRC §6330 |
| Triggering notice | CP504, IA rejection, lien filing, levy action | LT11, Letter 1058, Letter 3172 |
| Filing window | 3-4 business days after manager conference | 30 days from the date printed on the notice to request a hearing — not the day it reached you. |
| Tax Court review | None | Yes — IRC §6330(d)(1) |
| Speed | 1-4 weeks | 3-12 months |
| Scope | Collection action only | Underlying liability + collection alternatives |
CAP procedural requirement — manager conference first
Before filing Form 9423, the taxpayer must first request a conference with the Collection manager — this is procedurally mandatory. If the manager conference does not resolve the matter, Form 9423 must be received or postmarked within 3-4 business days of the manager conference. Missing this window forfeits CAP rights for that collection action.
The four strategic responses
Resolve now. Or wait for LT11 and resolve in a harder procedural posture.
Pay in full
Full payment closes the case and stops all collection authority. The IRS releases any pending levy action and stops the escalation to LT11. Available at IRS.gov: Direct Pay, EFTPS, debit card, credit card. Retain confirmation.
Streamlined Installment Agreement — IRC §6159
For individuals owing $50,000 or less (in-business taxpayers: $25,000 or less) with all returns filed, a streamlined IA under IRM 5.14.5 is often available online without a financial statement. IA approval triggers IRC §6331(k)(2) levy prohibition — the IRS may not levy while a properly-functioning IA is in place.
Currently Not Collectible (CNC) status
For taxpayers whose income does not exceed allowable living expenses under current IRS ALE standards, CNC status under IRM 5.16.1 pauses active enforcement such as levies. Refunds are still offset and a lien may be filed. Requires Form 433-A or 433-F documentation. CSED continues to run. Strategic for taxpayers within 3-4 years of CSED expiration.
Offer in Compromise — IRC §7122
For taxpayers whose Reasonable Collection Potential is substantially less than the assessed liability. Filing Form 656 with Form 433-A(OIC), the $205 application fee and the required payment (20% of a lump-sum offer, or the first proposed periodic payment) triggers IRC §6331(k)(1): levy is prohibited while the offer is pending. The fee and payment are waived if you meet the low-income certification. The CSED is suspended while the offer is pending and for 30 days after rejection (plus any appeal) under IRC §6331(k)(3). Typical pendency is 6–12 months.
Transparent pricing — CP504 engagements
| Service | Fee |
|---|---|
| Notice Review | $97 |
| Case Analysis | Case Analysis: $497 |
| Resolution work | Fixed by work type and amount owed |
| Representation (Form 2848) | $1,000 |
Case Analysis is $497 regardless of balance owed, tax years, complexity or urgency. The $97 Notice Review is credited toward the $497 Case Analysis. The $150 Transcript Pull is a separate service and is not credited. 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.
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.
Common questions about CP504
Ebot Mbi, CPA, EA
Texas CPA #127163 · IRS Enrolled Agent · 4425 West Airport Freeway, Suite 595, Irving, TX 75062
What comes next — downstream pages
Notice in hand right now?
Send the CP504 or CP504B. We review it the same business day, identify whether LT11 has also been issued, scope the engagement, and prepare the appropriate resolution path — payment, IA, CNC, CAP appeal — once the engagement letter is signed.
Start Notice Review →Studying notice sequencing for your EA exam?
The full practitioner walkthrough — §6331(d) framework, SITLP and FPLP automated levy procedures, CAP vs CDP comparison, the FAST Act passport certification framework, and Bluebook citation index — is on the practitioner page.
Read the practitioner pageLast updated: