You submitted a request for a Collection Due Process (CDP) hearing. However, your request was not filed within the 30 days of the date of mailing of the CDP notice as required by Internal Revenue Code (IRC) section 6320 and/or 6330. You received an Equivalent Hearing which is  a hearing equivalent to a CDP hearing and the IRS Independent Office of Appeals (Appeals) made a decision on your appeal request. You cannot dispute Appeals in an Equivalent Hearing decision in the U.S. Tax Court. 

You have a balance due on your tax account. The IRS has either issued you a CDP levy notice or filed a Notice of Federal Tax Lien (NFTL) providing CDP appeal rights. You have exercised your appeal rights and made a request for a CDP hearing after the due date for a timely hearing. You were entitled to an Equivalent Hearing with Appeals within the one-year period starting after the date of the CDP levy notice or, with respect to CDP lien cases, within the one-year period commencing the day after the end of the five-business-day period following the filing of the NFTL. Appeals made a decision on your appeal request.

If you have questions, you can contact the person shown at the top of the letter. You cannot dispute an Appeals Equivalent Hearing decision regarding the collection action (NFTL filing or levy) in the U.S. Tax Court because your appeal request was not filed within 30 days from the date of mailing of the CDP notice as required by IRC section 6320 and/or 6330.

Your account will be returned to Collection for action consistent with Appeals’ decision. You may want to review information regarding the following enforcement actions:

• Levies
• Liens

If you can’t pay the full amount, you can consider what payment options might work for your situation. You could review information regarding the following collection alternatives and resolutions:

• Installment agreement
• Offer in compromise
• Currently not collectible

If you agreed to a collection alternative such as an installment agreement or offer in compromise, you’ll need to make payments based on your agreement with the IRS. You’ll also need to stay current in filing and paying your taxes during the time of the agreement, and if you enter into an offer in compromise, for five years after the IRS accepts your offer.

If you believe that you timely filed your CDP hearing request and you can provide proof of timely filing, you can file a petition with the U.S. Tax Court within 30 days from the date of this letter to dispute Appeals’ decision about the timeliness of your hearing request.

To obtain a petition form and the rules for filing a petition, you can visit the U.S. Tax Court website.

If you think you’ll have trouble paying your taxes or the NFTL filing will cause economic hardship, it’s helpful to know what your options are to address your tax debt.