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Pre-Levy vs. Post-Levy Hearing Notices

Both say you have a Collection Due Process right. On one the levy has not happened yet. On the other it already has, and the notice says why there was no warning.

Quick Answer

Read the tense of the first sentence. "We intend to levy" and "we levied your assets" are the same eleven-word structure and they describe opposite positions. Both carry a Collection Due Process right; only one of them carries it before anything is taken. The post-levy notices are the more interesting of the two, because each names the statutory exception it relied on and the exceptions are different — an earlier hearing within the last two years on an adjacent period, or federal contractor status under section 6330(f). Which notice you received tells you which rule the IRS applied. What none of them tells you is a deadline: no IRS page in this set states a number of days, and for a post-levy opportunity the statute gives it "within a reasonable period of time after the levy" and publishes no figure at all.

1

Pre-levy notice (CP90, CP297, LT11, CP77, CP177, CP298)

Advantages

  • The hearing comes first. The IRS states it intends to levy and informs you of the right in the same notice.
  • A timely request prohibits levy while it is pending, unless a section 6330(f) exception applies.
  • IRM 5.1.19 states the collection statute is suspended while a timely request runs.
  • There is time to arrange something before anything is taken.

Disadvantages

  • The window is short and the date is on the notice.
  • Miss it and what remains is an equivalent hearing, which does not prohibit levy and does not suspend the statute.
  • The IRS issues these under several designations, which makes them easy to mistake for one another.

Best For

What has happened: the IRS has stated an intention. Nothing has been taken.

Typical Cost

No fee attaches to any of these notices.

VS
2

Post-levy notice (CP90C, CP297A, CP297C, CP92, CP242)

Advantages

  • The right is not lost. Every one of these notices states you have a Collection Due Process hearing right.
  • The IRS names the exception it relied on, which tells you which rule is in play.
  • On CP90C the IRS states you can submit Form 12153 through the Document Upload Tool with the access code on your notice.

Disadvantages

  • The levy has already been made. These notices report rather than warn.
  • The reasons differ and are not interchangeable. CP297A: "you (or your predecessor) already requested an earlier hearing within the last two years for a period that ended with the beginning of the period shown on the notice." CP297C: "Federal contractors do not have the right to a pre-levy hearing." CP90C: the same contractor exception under IRC 6330(f).
  • None of these IRS pages states a number of days. The date is on the notice, and the 30-day figure associated with a pre-levy notice does not transfer.

Best For

What has happened: property has been taken, and the notice explains why no hearing came first.

Typical Cost

No fee attaches to any of these notices.

The Verdict

Read the tense of the first sentence. "We intend to levy" and "we levied your assets" are the same eleven-word structure and they describe opposite positions. Both carry a Collection Due Process right; only one of them carries it before anything is taken. The post-levy notices are the more interesting of the two, because each names the statutory exception it relied on and the exceptions are different — an earlier hearing within the last two years on an adjacent period, or federal contractor status under section 6330(f). Which notice you received tells you which rule the IRS applied. What none of them tells you is a deadline: no IRS page in this set states a number of days, and for a post-levy opportunity the statute gives it "within a reasonable period of time after the levy" and publishes no figure at all.

Frequently Asked Questions

The levy already happened. Is the hearing gone?
No. CP90C, CP297A, CP297C, CP92 and CP242 all state you have a Collection Due Process hearing right. It arrives after the levy rather than before it.
Why was there no hearing first?
It depends which notice you received, and they give different reasons. CP297A points to an earlier hearing requested within the last two years on an adjacent period. CP297C states federal contractors do not have a pre-levy right. CP90C gives the same contractor exception with its basis, IRC 6330(f). CP92 and CP242 involve a state tax refund, which section 6330(f)(2) excepts.
How long do I have on a post-levy notice?
No IRS page in this set states a number of days. The date is on your notice. Do not carry across the 30-day figure from a pre-levy notice — it attaches to a different provision.
Which notices are pre-levy?
CP90, CP297, LT11 and Letter 1058, CP77, CP177 and CP298 all state an intention to levy. CP504 is a Notice of Intent to Levy under a different section and does NOT carry a Collection Due Process right.

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Sources

Sourced to primary IRS materials and editorially reviewed. Not reviewed by a tax professional. Not tax advice. Report a correction.