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. After 30 days from the date of CP504, the IRS may 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.
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 · base fee $650 · free same-day notice review.
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 CDP notice |
| 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 balances ≤$50,000 with all returns filed, a streamlined IA under IRM 5.14.5 is typically approvable within 1-3 business days. 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 stops collection enforcement. 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 and Form 433-A(OIC) triggers IRC §6331(k)(1) — levy is prohibited during OIC processing. CSED tolled under IRC §6503(a). Typical pendency 6-12 months.
Transparent pricing — CP504 engagements
| Service | Fee |
|---|---|
| Base resolution scoping + transcript pull | $650 |
| Streamlined IA setup (under $50K, returns filed) | $1,000 – $1,500 |
| Full-pay IA with Form 433 analysis | $1,500 – $2,500 |
| CNC status (Form 433 + Form 2848) | $1,500 – $2,500 |
| CAP appeal (Form 9423) | $1,500 – $3,000 |
| Pre-CDP resolution package (full-spectrum) | $2,500 – $3,500 |
| Unfiled return preparation (per year) | $500 – $2,500 |
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 W Airport Fwy Ste 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.
Email Notice →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: September 7, 2026
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