Which IRS notices give you Collection Due Process rights?
Not the one most people think. CP504 is not among them.
Publication 1660 is the IRS publication that lists them, and the practical test is simpler than the list: a notice that carries a Collection Due Process right says so on its face. If it does not mention a Collection Due Process hearing, Form 12153 or Publication 1660, it is not that notice.
The notices that do carry it are the section 6330 levy notices and the section 6320 lien notice: CP90, CP297, LT11 — which the IRS also issues as Letter 1058 and as Letter 11 — and Letter 3172, the Notice of Federal Tax Lien filing notice. Several post-levy notices carry it too, after the fact: CP90C, CP297A, CP297C, CP92 and CP242.
CP504 does not. It satisfies Internal Revenue Code section 6331(d), which requires written notice before a levy. That is a different section from 6330, which is the one that comes with a hearing. The CP504 page never mentions CDP, Form 12153 or Publication 1660, and the appeal route the IRS names on it is the Collection Appeals Program instead.
This site published the confusion. /notices/cp504/ told readers to request a Collection Due Process hearing on a notice that does not confer one, and it did so on the second most-viewed page on the property. The error runs both ways: someone who thinks CP504 is their hearing notice waits for a right they were never offered, and someone who thinks the Final Notice is just another reminder lets a real one expire.
The records this answer comes from
This page exists because no single one of those answers the question on its own. No single notice page answers this, because the answer is a comparison across six of them plus a publication. It is also the question behind the most consequential error this site has published.
Sources
- Publication 1660, Collection Appeal Rights — Internal Revenue Service, retrieved 2026-08-21
- Understanding your CP504 notice — Internal Revenue Service, retrieved 2026-08-21
- 26 U.S.C. §6330 — Notice and opportunity for hearing before levy — United States Code, retrieved 2026-08-21
Sourced to primary IRS materials and editorially reviewed. Not reviewed by a tax professional. Not tax advice.