Collection notice
Washington, DC IRS collections lawyer for liens and levies.
Mr. Powell is a Washington, DC IRS collections attorney for unpaid tax balances, federal tax liens, levies, LT11 and Letter 1058, and the payment options the IRS offers.
Which notice is in hand?
- LT11 or Letter 1058. Final notice of intent to levy. Form 12153 within 30 days from the notice date.
- Letter 3172. Notice of federal tax lien filing. Section 6320 hearing window after the five-business-day period; the printed date on the notice controls.
- CP504. Notice of intent to levy (often a state tax refund). Levy warning that often precedes LT11.
- IRS Letter Check. Look up another supported letter code, then return for the collections path.
Collection Due Process.
He answers the final notice, requests the Collection Due Process hearing on Form 12153, and takes the case to the IRS Independent Office of Appeals. LT11 and Letter 1058 are final notices of intent to levy. 26 U.S.C. section 6330 gives a 30-day window to request a Collection Due Process hearing after a final notice of intent to levy, and section 6320 gives a 30-day window after a Notice of Federal Tax Lien filing, running from the end of the five-business-day period after the filing. A timely levy hearing request generally suspends the levy actions at issue under section 6330(e)(1). A lien hearing request does not by itself stop a levy. Either request preserves Tax Court review under section 6330(d)(1). The date printed on the notice controls; do not use this page to calculate it.
The firm has an office at 1629 K Street NW, Suite 300 in Washington, DC and represents individuals and closely held businesses in IRS collection matters nationwide.
Each matter begins with the collection notice, the assessed balance, and any lien, levy, or hearing deadline shown on the letter.
The collection procedures described on this page were checked on irs.gov and uscode.house.gov on September 4, 2026. The lien and levy hearing rules and the collection statute were rechecked against 26 U.S.C. sections 6320, 6330, and 6502 and Internal Revenue Manual 5.1.19 on September 10, 2026. The equivalent-hearing rule in Treasury Regulation 301.6330-1(i), the CP523 default notice, and the currently not collectible description were checked on ecfr.gov and irs.gov on September 16, 2026. The first-screen notice map was revised on September 19, 2026. The notice in hand controls over this summary.
What are the options when a tax debt cannot be paid in full?
If a tax debt cannot be paid in full, the IRS describes options that may include a payment plan, an offer in compromise, a temporary delay of collection, and penalty relief. Most payment plans and relief options require that required tax returns are filed.
For a Maryland resident, a Chapter 13 plan can also pay priority tax debt over time under court supervision; see Chapter 13 for IRS back taxes.
A federal tax lien is the government’s legal claim against property after the IRS assesses a liability, sends a bill, and the tax remains unpaid. A levy is different. A levy takes property to pay the tax. The paper notice controls which of those steps the IRS says it is taking.
The lien, the levy, and the collection period each have their own section. 26 U.S.C. section 6321 creates a lien in favor of the United States on all property of a taxpayer who neglects or refuses to pay after notice and demand, and section 6331 authorizes collection of that assessment by levy. Under 26 U.S.C. section 6502 the IRS generally has 10 years from the date of assessment to collect by levy or by a court proceeding, and that period can be suspended by later events, including a pending installment-agreement request, a pending offer, a Collection Due Process hearing, and bankruptcy. The assessment date on the account fixes when that period began; this page does not compute it.
Official source: Get help with tax debt
Official source: Understanding a federal tax lien
Official source: What is a levy
Official source: 26 U.S.C. 6330, notice and opportunity for hearing before levy
Official source: 26 U.S.C. 6320, notice and opportunity for hearing upon filing of notice of lien
Official source: 26 U.S.C. 6321, lien for taxes
Official source: 26 U.S.C. 6331, levy and distraint
Official source: 26 U.S.C. 6502, collection after assessment
The work
Read the notice.
Read the notice
Identify the tax years, the assessed balance, any lien or levy warning, hearing rights, and the response deadline printed on the letter.
Reconcile the account
Compare the IRS balance with filed returns, prior payments, credits, and any open examination or appeal.
Identify available options
The IRS describes payment, installment agreements, offer in compromise, a temporary delay of collection, and penalty relief as possible paths, subject to eligibility.
Protect hearing rights
If the notice offers a Collection Due Process hearing, calendar the date printed on the letter and follow the request instructions in that notice.
Payment options and hearing rights.
IRS installment agreements allow payment over time when the taxpayer qualifies. An offer in compromise is a separate program to settle a tax debt for less than the full amount if the taxpayer qualifies. Each of those options, and currently not collectible status, starts from a Collection Information Statement on Form 433-A, 433-B, or 433-F, which the IRS measures against its Collection Financial Standards. Compare offer in compromise vs installment agreement, read alternatives to an offer in compromise, and see Collection Due Process vs equivalent hearing for hearing rights. Eligibility depends on the account, filing compliance, and the IRS’s collection analysis. This page does not determine whether any option is available in a particular matter.
LT11 and Letter 1058 are final notices of intent to levy and notices of a right to a Collection Due Process hearing. The IRS says to request that hearing on Form 12153 within 30 days from the date of the letter. A request received after that period can still ask for an equivalent hearing within one year under Treasury Regulation 301.6330-1(i), which ends in a decision letter with no Tax Court review and does not suspend the levy. Read Collection Due Process vs equivalent hearing for that choice. The date and instructions on the notice control. Do not use this page to calculate that deadline.
An installment agreement is requested online or on Form 9465. A CP523 notice states that the IRS intends to terminate an existing agreement and levy because the agreement is in default, and the IRS says to contact it no later than 30 days from the date of that notice. Where the financial statement shows no ability to pay, the IRS can report the account as currently not collectible; penalties and interest continue to accrue and the IRS may still file a Notice of Federal Tax Lien.
Some collection actions also qualify for the Collection Appeals Program. IRS Publication 1660 explains the difference. Using one hearing path can limit what another hearing can consider.
Official source: Payment plans
Official source: Offer in compromise
Official source: Collection Due Process FAQs
Official source: Requesting an appeal
Official source: IRS Publication 1660
Official source: IRS Publication 594
Official source: Treasury Regulation 301.6330-1, equivalent hearing
Official source: Temporarily delay the collection process
Questions
Common questions.
What does an IRS collections attorney in Washington, DC handle?
An IRS collections attorney represents individuals and closely held businesses facing an unpaid tax balance, a federal tax lien, a levy, or a payment option. Law Office of Alexander Powell, PLLC has an office at 1629 K Street NW, Suite 300 in Washington, DC and represents those clients in IRS collection matters nationwide. Each matter begins with the collection notice, the assessed balance, and any lien, levy, or hearing deadline shown on the letter.
What is the difference between an IRS tax lien and an IRS levy?
26 U.S.C. section 6321 creates a lien in favor of the United States on all property of a taxpayer who neglects or refuses to pay after notice and demand, so the lien is a legal claim against property. Section 6331 authorizes collection of that assessment by levy, and a levy takes the property. The hearing rights differ too. Section 6320 gives 30 days to request a Collection Due Process hearing after a Notice of Federal Tax Lien filing, and section 6330 gives 30 days after a final notice of intent to levy.
What payment options does the IRS describe for unpaid tax?
Where a tax debt cannot be paid in full, the IRS describes a payment plan, an offer in compromise, a temporary delay of collection, and penalty relief. An individual owing $50,000 or less in combined tax, penalties, and interest, with required returns filed, can set up a payment plan online. Most payment plans and relief options require that the required tax returns are filed. An installment agreement does not extend the collection period, and the Internal Revenue Manual states that the collection statute is not suspended while an agreement is in effect.
What is a Collection Due Process hearing?
A Collection Due Process hearing is a review by the IRS Independent Office of Appeals of a lien filing or a proposed levy. LT11 and Letter 1058 are final notices of intent to levy and notices of that right, and 26 U.S.C. section 6330 gives 30 days from the date of the letter to request the hearing on Form 12153. A timely levy request generally suspends the levy actions at issue and preserves Tax Court review under section 6330(d)(1). A lien hearing request does not by itself stop a levy. The date and instructions on the notice control.
How long does the IRS have to collect?
Under 26 U.S.C. section 6502 the IRS generally has 10 years from the date of assessment to collect by levy or by a court proceeding. That period can be suspended by later events, including a pending installment-agreement request, a pending offer in compromise, a Collection Due Process hearing, and bankruptcy. The assessment date on the account fixes when the period began, and the transcript rather than any summary shows where it stands. This page does not compute it.
What happens if the 30 days to request a Collection Due Process hearing have passed?
The taxpayer can still request an equivalent hearing with the IRS Independent Office of Appeals. Treasury Regulation 301.6330-1(i) sets the window at one year, running from the day after the date of the levy notice or, for a lien, from the day after the five-business-day period that follows the lien filing. The equivalent hearing follows substantially the same procedures and ends in a decision letter. There is no Tax Court review of that decision, and the request does not suspend the levy or the collection period. The date printed on the notice controls.
What is currently not collectible status?
Currently not collectible status is the IRS description for an account it has decided not to collect on for now because the Collection Information Statement shows the taxpayer cannot pay any of the debt without leaving basic living expenses unmet. The IRS states that the debt does not go away, that penalties and interest continue to accrue, that it may file a Notice of Federal Tax Lien, and that it may review the financial situation later and resume collection if the ability to pay improves. Filing compliance is required, and the collection period under 26 U.S.C. section 6502 keeps running.
Is an offer in compromise the same as an installment agreement?
No. An installment agreement pays the assessed liability over time when the taxpayer qualifies. An offer in compromise asks the IRS to accept less than the full amount, carries a $205 application fee waived on a low-income certification, and is evaluated against the IRS collection analysis. Penalty relief is a third path again, resting on reasonable cause under Internal Revenue Code section 6651(a) or on the First-Time Abate administrative waiver. Eligibility depends on the account, filing compliance, and that analysis.
What may follow a collection notice.
Start with How do I respond to an IRS collection notice? when the question is what to do with the paper in hand. The next step depends on the document the IRS issued. A balance-due series such as CP14, CP501, or CP504 may precede levy action. Letter 3172 concerns a Notice of Federal Tax Lien. A Collection Due Process request, if available, is heard by the IRS Independent Office of Appeals. Read IRS Appeals for that review function. Read IRS levy and offer in compromise when those are the collection issues.
If the balance still depends on an examination, start with IRS audit defense. Use the IRS Letter Check for a supported notice code.
Related pages
Related IRS collections resources.
- Washington, DC tax attorneyIRS examinations, appeals, collections, penalties, and U.S. Tax Court from the Washington, DC office.
- IRS AppealsRead how the firm approaches review by the IRS Independent Office of Appeals, including collection hearing rights.
- IRS audit defenseReturn to the examination hub when the balance still depends on an open or disputed audit.
- How do I respond to an IRS collection notice?Read the paper notice first. Identify the letter code, the assessed balance, and any date printed on it.
- IRS levyRead how the firm approaches wage levies, bank levies, and notices of intent to levy.
- IRS Form 433-A and 433-BThe Collection Information Statement: which form applies, the expense standards, equity in assets, and how it drives the payment option.
- IRS installment agreementAgreement types, Form 9465, user fees, the levy bar, and default.
- Trust fund recovery penaltyThe personal penalty for unpaid payroll trust fund taxes, with the Form 4180 interview and Letter 1153 appeal.
- Offer in compromiseRead how the firm approaches an IRS offer to settle a tax debt for less than the full amount.
- Penalty reliefRead how the firm approaches IRS penalty disputes and requests for relief.
- CP504Notice of intent to levy.
- LT11 or Letter 1058Final notice of intent to levy and Collection Due Process hearing rights.
- Letter 3172Notice of federal tax lien filing.
- Federal tax lienRelease, withdrawal, discharge, subordination, and how long a lien lasts.
- Currently Not Collectible statusThe IRS hardship status: what it suspends, what it does not, and how an account is reactivated.
- Passport certificationSection 7345 certification of seriously delinquent tax debt, and how it is reversed.
- Innocent spouse reliefForm 8857 and the three kinds of relief from a joint return.
- IRS Form 12153The Collection Due Process hearing request, item by item.
- IRS Letter CheckLook up the code printed on a supported IRS letter.
- Tax attorney vs CPAWhat each credential can do at exam, collections, and Appeals, compared.
- Audit vs collection caseAn examination questions the return; a collection case enforces an assessed balance.
Send the letter code and the date printed on it.
Tell me what the collection notice says, the balance shown, and any hearing or payment date printed on it. Send only a high-level summary.
Schedule an initial consultationRequesting a consultation does not make Mr. Powell your lawyer, provide legal advice, or protect a deadline.
Law Office of Alexander Powell, PLLC. 1629 K Street NW, Suite 300, Washington, DC 20006.