Notice CP90: IRS Notice CP90 — Final Notice of Intent to Levy
Notice CP90 is one of the most serious letters the IRS sends. This is not a warning that something might happen — it's a legal notification that the IRS intends to seize your assets. Bank accounts. Wages. Real property. Personal property. The government has decided that collection action is imminent, and it is giving you 30 days to exercise your legal rights before it acts.
What CP90 Triggers Under Federal Law
Under IRC § 6330, before the IRS can levy property, it must send a Final Notice of Intent to Levy and advise you of your right to a Collection Due Process (CDP) hearing. CP90 is that notice. The 30-day clock starts from the notice date — not when you receive it. That distinction matters.
Your Right to a CDP Hearing — Use It
Filing for a CDP hearing via Form 12153 within 30 days does several important things:
It legally halts the levy while your hearing is pending
It gives you the right to propose collection alternatives (payment plans, Offer in Compromise, Currently Not Collectible status)
It preserves your right to petition the U.S. Tax Court if Appeals denies your request
Missing the 30-day deadline doesn't eliminate all rights, but it downgrades your hearing to an "Equivalent Hearing" — which does NOT stop the levy and does NOT give you Tax Court access.
Your 3-Step Action Checklist
File Form 12153 immediately.
Mail it to the address on the notice. Use Certified Mail with return receipt. You need proof of timely filing.
Request a CDP Hearing.
Check the box for collection alternatives. Be prepared to propose a payment plan or demonstrate hardship.
Do not ignore this notice. Every day of inaction increases the IRS's ability to act unilaterally.
What the IRS Can Seize
Under IRC § 6331, the IRS can levy virtually any asset: checking and savings accounts, wages, retirement accounts, Social Security benefits, accounts receivable (for businesses), real estate, and vehicles.
How We Stop a Levy
Our attorneys file your CDP request immediately, gather your financial documentation, and present your case to IRS Appeals in the most favorable light possible. We've helped clients stop bank levies, release wage garnishments, and negotiate resolutions that let them keep their assets and get back into compliance.
Call us the day you receive CP90. Time is the most important resource you have.