IRS collection notices typically arrive in this order, though it is the usual progression rather than a required one, and a given account can skip or repeat a step: CP14 (the bill), CP501 and CP503 (reminders), CP504 (intent to levy a state refund), then LT11 or Letter 1058 (final notice with hearing rights). Collection Due Process rights attach at that final notice, and the IRS cannot levy wages or bank accounts until the 30-day request window on it has run.
Clients bring the envelope in late. Usually it is the third or fourth one. By then "what do I owe" has stopped being the question, and what they want to know is what the IRS has already done and what it is allowed to do next. The sequence below answers that. I have tied each claim to the statute or the irs.gov notice page it comes from, so you can hand it to a client and point at the line.
For an individual with an assessed balance, the automated stream runs CP14, CP501, CP503, CP504, then LT11 (or Letter 1058 when a revenue officer has the case). The IRS does not publish a fixed number of days between the reminders. I have watched the gap stretch and shrink with IRS staffing over the years, so plan around the due date printed on each notice and ignore whatever calendar you remember from a prior client.
A couple of things trip people up here, practitioners included. The CP14 is a bill for a balance the IRS has already assessed, so arguing figures on it gets you nowhere. That argument belongs earlier, at the proposal stage, or later through the right procedural door. And the lien and the levy run on separate tracks. The statutory lien under IRC 6321 exists the moment a taxpayer "neglects or refuses to pay the same after demand," which is long before anything gets recorded at the county.
| Notice | What it says | What changes | What the taxpayer can do | Deadline language (per irs.gov) |
|---|---|---|---|---|
| CP14 | You owe money on unpaid taxes. | Balance is assessed. Interest and the failure-to-pay penalty run from the original due date. | Pay, set up a payment plan, or contact the IRS if you disagree with the assessment. | "Pay by the due date on the notice." |
| CP501 | A reminder that you owe a balance on one of your tax accounts. | The IRS states it can file a Notice of Federal Tax Lien if you do not pay or make arrangements. | Pay, apply for an installment agreement online or on Form 9465, call the number on the notice to dispute. | "Pay the amount you owe by the due date shown on the notice." |
| CP503 | Second reminder of the same balance. | Same lien warning, now phrased "if we haven't already done so." Still no levy authority. | Same options. Call by the payment due date to reach a representative. | "Pay the entire balance by the due date shown on your notice." |
| CP504 | Notice of Intent to Levy under IRC 6331(d). | The IRS can seize any state tax refund you are owed and begins searching for other assets. | Pay, propose a plan, or request a Collection Appeals Program (CAP) review per the notice. | "Pay the amount you owe immediately." |
| LT11 / Letter 1058 | Final notice of intent to levy and notice of your right to a hearing. | Collection Due Process rights attach. After the window closes, wages, bank accounts, and other property are reachable. | File Form 12153 for a CDP hearing, pay, or set up an installment agreement if filings are current. | "You must contact us immediately." The hearing window is in the letter's instructions. |
The 30 days is not printed on any of those pages. It comes from the Code. IRC 6330(a) requires the hearing notice "not less than 30 days before the day of the first levy," and IRC 6331(d) separately requires written notice of intent "no less than 30 days before the day of the levy." When a client asks where the deadline comes from, cite the statute rather than the envelope.
Both say "intent to levy," and clients treat them as the same letter. I have had clients bring me a CP504 convinced it was the final notice, and others sit on an LT11 because they assumed another warning was coming. Neither assumption is right.
CP504 satisfies the IRC 6331(d) notice requirement. Per its irs.gov page, the asset it reaches directly is the state tax refund, and the page says the IRS "will begin searching for other assets to levy." The appeal route it names is the Collection Appeals Program, an administrative review with no path to Tax Court.
LT11 (and Letter 1058, its revenue-officer twin) is the IRC 6330 notice. It carries the right to a Collection Due Process hearing before the IRS Independent Office of Appeals, requested on Form 12153. A timely request suspends the levy actions under review and tolls the collection statute while the hearing and any appeal are pending, per IRC 6330(e). Of everything in this sequence, that suspension is the right I would least want a client to lose, and it is the one they let lapse most often.
There are two triggers, one on the levy side and one on the lien side, and they do not share a window.
On the levy side, rights attach with the LT11 or Letter 1058. The 30-day period in IRC 6330(a)(3)(B) runs from that notice.
On the lien side, rights attach after a Notice of Federal Tax Lien has been filed. IRC 6320(a) requires the IRS to tell the taxpayer "not more than 5 business days after the day of the filing," and the hearing request period is the 30 days beginning the day after that 5-day window. The lien notice is Letter 3172.
Miss either window and the taxpayer can still ask for an equivalent hearing on the same Form 12153, without the levy suspension and without judicial review. A late request is not always the end of the road, though. In Organic Cannabis Foundation v. Commissioner, 161 T.C. No. 4 (2023), the Tax Court held that the 30-day period to request a hearing is subject to equitable tolling, so in unusual circumstances a late request can be treated as timely. The bar is high, and most taxpayers who have argued it since have lost. In my experience, whether the request went in on time matters more to how a case goes than any reasonable-cause argument I have ever written.
Per the IRS's own explainer, the lien is "the government's legal claim against your property when you neglect or fail to pay a tax debt." It attaches to all property and rights to property, real and personal, including assets acquired after the lien arose. The Notice of Federal Tax Lien is the public filing, recorded at the county, that establishes priority against other creditors under IRC 6323.
The same irs.gov page puts the two side by side: the lien secures the government's interest in the property, and the levy is what takes it. A client with a recorded lien has not lost anything yet. A client with a wage levy is losing part of every paycheck, and usually has been for a while before they call.
IRC 6502(a)(1) gives the IRS 10 years after assessment to levy or begin a court proceeding. The date is per assessment, so a client with three unpaid years has three expiration dates, and they are rarely the dates the client thinks they are. Several events pause the clock, among them a pending CDP hearing (IRC 6330(e)), a pending installment-agreement request, an offer in compromise under consideration, and bankruptcy. Pull the account transcript before you advise anyone on this. The transcript shows the assessment date, which is where the IRS starts counting.
Each notice above is also a dated record that the IRS gave the taxpayer a chance. Ignore the CP14 and the reminders and the balance keeps accruing interest and failure-to-pay penalty. Ignore the CP504 and the state refund is gone. Ignore the LT11 and, once the 30 days run, the IRS can levy wages, bank accounts, and the other property its notice page lists, with no further hearing required for those periods.
One more consequence, and it is the one clients never see coming. The LT11 page notes that the FAST Act "generally prohibits" the State Department from issuing or renewing a passport to a taxpayer with seriously delinquent tax debt. The threshold and the certification process are at IRC 7345.
Notices of Federal Tax Lien are public records, so the end of this sequence can be counted. Clarity Tax Relief, a tax relief firm in Orange County, California, pulled lien filings from county recorder indexes for Orange, Riverside, and San Diego counties across 2018 to 2025. All three counties trace the same curve.
| County | 2019 | 2022 | 2025 |
|---|---|---|---|
| Orange | 6,920 | 1,905 | 3,211 |
| Riverside | 5,051 | 1,029 | 2,340 |
| San Diego | 6,209 | 1,621 | 2,597 |
Filings fell 72% to 80% from 2019 to the 2022 floor, then climbed. From 2023 to 2025, Orange County rose 40.7%, San Diego 64.1%, and Riverside 117.7%. The three counties together recorded just over 8,100 liens in 2025, roughly 42% to 46% of each county's 2019 volume. The same page notes national lien counts from the IRS Data Book of 179,019, 196,996, and 214,099 for 2023 through 2025.
For an Orange County practice, the automated stream above is running at full speed again. The CP504 and LT11 letters that went quiet in 2020 are landing on desks (I see a few every week now), and each one carries a 30-day window that the statute set and nobody in this office can move.
Bizora AI turns hours of manual research into seconds, with every answer backed by primary source citations. Start your 7-day free trial. No credit card required.
Start Free TrialNo, and this is the one people get wrong most. CP504 is the IRC 6331(d) intent-to-levy notice. Per irs.gov it lets the IRS take a state tax refund while it looks for other assets. The final notice with Collection Due Process hearing rights is the LT11 or Letter 1058, issued under IRC 6330, and only that one starts the 30-day window to request a hearing on Form 12153.
Thirty, under IRC 6330(a), counted from the notice. The irs.gov LT11 page does not print a number anywhere, which surprises people. It refers you to the instructions on the letter. Get the request in on time and the levy under review is suspended, and the collection statute is tolled for as long as the hearing and any appeal run.
Not in the ordinary case. IRC 6331(d) requires written notice of intent to levy at least 30 days before a levy, and IRC 6330 requires notice of the right to a hearing in the same period. The exception is a jeopardy determination under IRC 6331(d)(3). A state tax refund is different, though. It can be taken after a CP504 without the second notice.
No. A lien is a claim that secures the government's interest in property and sets priority against other creditors. A levy is the act of taking property. The IRS's own lien explainer keeps the two apart. A lien can block a sale or refinance until it is dealt with, and that is a real cost, but nobody is coming for the house on the strength of a lien alone.
A timely request under IRC 6330 suspends the levy actions that are the subject of the hearing, and the collection statute is tolled while the hearing and appeals are pending, per subsection (e). Interest keeps running the whole time, and a lien that is already recorded stays recorded. A late request, which the IRS treats as an equivalent hearing, carries no suspension at all.
Yes. The LT11 page says a taxpayer who is current on filings and owes under $50,000 may be able to set up an installment agreement. The usual way to keep a levy from being served is to propose the plan inside the 30-day window, or raise it as a collection alternative at the CDP hearing, so the IRS is considering it rather than levying.
Related articles