An official website of the U.S. GovtDecision Letter Concerning Equivalent Hearing Under Internal Revenue Code (IRC) Section 6320 and/or 6330 and Notice of Final Determination on Your Interest Abatement Claim Under IRC Section 6404
This letter is issued to the taxpayer when the IRS Independent Office of Appeals (Appeals) makes a determination on the taxpayers Collection Due Process (CDP) Equivalent Hearing request and interest abatement request.
You submitted a request to Appeals for a CDP equivalent hearing. Appeals made a decision on your appeal request.
You have a balance owed on your tax account. The IRS has either issued you a notice of intent to levy with appeal rights or filed a Notice of Federal Tax Lien (NFTL). 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 within the one-year period with Appeals. Appeals made a decision on your appeal request. As part of your equivalent hearing request you also requested abatement of interest.
If you have questions, you can contact the person shown at the top of the letter.
Since your CDP request was not timely, you received an equivalent hearing and the IRS made a determination about your lien or levy. This decision cannot be reviewed further by the IRS or the Tax Court. However, as part of your CDP request, you raised an issue of interest abatement. The interest abatement issue can be appealed to the Tax Court. If you want to dispute the determination regarding your interest abatement request, you must file a petition with the Tax Court within 180 days from the date of the Letter 4440. The time you have to file a petition with the Tax Court is set by law and can’t be extended or suspended, even for reasonable cause. Neither the IRS nor TAS can change the allowable time for filing a petition with the Tax Court.
Your case will be returned to the IRS Collection function. You may want to review information regarding enforcement actions:
If you can’t pay the full amount, pay what you can, or you can consider what payment options might work for your situation, and act to set up a payment plan or other way to pay off your balance. You may want to review information regarding collection alternatives or temporary relief from collection, if applicable:
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