Independent Appeals review
The IRS Independent Office of Appeals reviews the proposed collection action and issues a determination.
LT11 is a final notice of intent to levy and notice of your right to request a Collection Due Process hearing. The IRS says it intends to seize property or rights to property because overdue taxes remain unpaid.
The hearing deadline is critical. Calling the IRS or booking a professional call does not, by itself, file a hearing request.
There is no fee to book the call. No documents are required when booking. Have every page and enclosure from LT11 available during your call.
LT11 generally follows earlier balance-due and collection notices. It satisfies the requirement to notify the taxpayer of the proposed levy and the right to a hearing before most levy action.
A levy is a legal seizure of property. It is different from a federal tax lien, which is a legal claim against property.
The IRS Independent Office of Appeals reviews the proposed collection action and issues a determination.
The taxpayer may propose an installment agreement, offer in compromise, currently not collectible status, or another available alternative.
The taxpayer may raise appropriate challenges involving payment application, procedural compliance, or whether the proposed action balances collection needs with intrusiveness.
The underlying liability may generally be challenged only when the taxpayer did not receive a statutory notice of deficiency and otherwise had no prior opportunity to dispute it.
A timely request generally suspends levy action for the listed periods while the CDP matter is pending, subject to statutory exceptions.
A timely CDP request may preserve the right to seek U.S. Tax Court review after Appeals issues its determination.
Identify each tax year, form, and balance covered by LT11. A hearing request should clearly identify the periods being appealed.
State the collection alternative or dispute being raised and explain why the proposed levy should not proceed.
Use the address or fax number shown on LT11. Keep certified-mail proof, fax confirmation, or another reliable filing record.
A late request may generally be treated as an Equivalent Hearing if submitted within one year from the date of the levy notice.
An Equivalent Hearing generally does not suspend levy action and does not provide the same right to petition the U.S. Tax Court if the taxpayer disagrees with Appeals.
Yes. LT11 generally provides the formal right to request a Collection Due Process hearing before most levy action.
No. A telephone call does not substitute for a timely written CDP request when a hearing is needed.
Form 12153 is commonly used. Follow LT11 instructions and identify the tax periods, collection issues, and requested alternative.
Only in limited circumstances, including when there was no prior opportunity to dispute the underlying liability.
No. There is no fee to book the call. Professional work requires a separate written engagement.
Representation may be offered after the notice, deadlines, account history, compliance status, finances, and hearing issues are reviewed.
This page was reviewed on July 26, 2026. Always follow the dates and instructions printed on your actual notice.
Book a call with TaxDecoders. Have the complete notice and the exact hearing deadline available during the call.
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