Final Notice of Intent to Levy (CP90)

Everything before this point, the CP14, the reminders, even the CP504, was pressure. The CP90 is authority. It is the statutory final notice that, once 30 days pass, lets the IRS execute a levy against your property: wage garnishment, a bank levy, and seizure of other assets including federal payments. The CP90 also carries the passport warning: unresolved debt at this level can be certified as seriously delinquent tax debt, which generally blocks passport issuance and renewal via a CP508C.

Filing Form 12153, Request for a Collection Due Process or Equivalent Hearing, within 30 days of the notice date does three big things:

• It generally stops levy action on the periods at issue while Appeals considers your case.
• It gets you in front of the Independent Office of Appeals, where you can propose an installment agreement, an offer in compromise, or currently not collectible status, and in some cases dispute the underlying liability if you never had a prior chance.
• It preserves your right to U.S. Tax Court review if you disagree with the Appeals determination. That judicial backstop only exists for timely requests.

Miss the 30 days and you can still request an equivalent hearing for up to one year, but levy action is not required to stop and there is no Tax Court review of the outcome. The trade-off to know: a timely CDP request also suspends the 10-year collection statute while the hearing is pending.

After the 30 days, the IRS can levy wages, bank accounts, and other property, and it does not need to warn you again before each levy. Garnishments hit employers directly, bank levies freeze funds on the day they are served, and both tend to surface at the worst possible moment. Our guides on stopping wage garnishment and bank levies cover the after-the-fact remedies, but every one of them is harder than filing one form inside the window. This is the stage where professional help pays for itself fastest; a free consultation with a resolution specialist on our team can tell you within a day which path fits your facts.

Three moves, in order of urgency:

1. Calendar the 30-day date from the notice date and treat it as immovable.
2. Decide your resolution proposal before filing. A CDP hearing goes far better when you arrive with a concrete alternative: a payment plan you can sustain, an offer backed by a completed Form 433-A, or hardship documentation.
3. File Form 12153 by the deadline, using the address on your notice or the IRS Document Upload Tool with your notice access code.

If you agree you owe and simply need terms, you can also skip the hearing and set up an agreement directly; the hearing right is leverage, not an obligation.