I received a final notice of intent to levy.
An LT11 or Letter 1058 is the final notice before the IRS can levy most property. It also carries a right that has a fixed window: a Collection Due Process hearing. The date of the letter matters more than anything else in it.
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30 days for a Collection Due Process hearing.
The law bars most levies until the IRS has notified you in writing of your right to a hearing, and gives you a 30-day period to request one.
The window
A hearing request must be made within the 30-day period beginning the day after the date of the notice. The notice itself states the deadline. The IRS's form for the request is Form 12153.
Law · IRC §6330(a)(3)(B); Treas. Reg. §301.6330-1(c) · Form: IRS practiceLevy is suspended
A timely request generally suspends the levy actions that are the subject of the hearing, and the IRS's collection period, while the hearing and any appeal are pending.
Law · IRC §6330(e)(1)An independent hearing officer
The hearing is held by the IRS Independent Office of Appeals, with an officer who has had no prior involvement with the unpaid tax, unless you waive that requirement.
Law · IRC §6330(b)(1), (3)Tax Court review
You may petition the Tax Court within 30 days of the Appeals determination.
Law · IRC §6330(d)(1)More than a protest.
You may raise any relevant issue about the unpaid tax or the proposed levy, including spousal defenses, whether the collection action is appropriate, and collection alternatives such as an installment agreement or an offer in compromise.Law · IRC §6330(c)(2)(A)
You can challenge the tax itself only if you did not receive a notice of deficiency for it and did not otherwise have an opportunity to dispute it.Law · IRC §6330(c)(2)(B)
Appeals must verify that legal and procedural requirements were met, and weigh whether the proposed levy balances efficient collection against your legitimate concern that it be no more intrusive than necessary. Generally, you are entitled to one hearing per tax period.Law · IRC §6330(b)(2), (c)(1), (c)(3)
The equivalent hearing.
A request made within one year beginning the day after the date of the notice can still receive an equivalent hearing with Appeals. It does not carry the same protections: the IRS is not required to suspend collection action (it decides case by case), the collection period keeps running, and the decision cannot be appealed to the Tax Court under §6330.Law · Treas. Reg. §301.6330-1(i)
The IRS also says levyable property can include wages, bank accounts, business and personal assets, state tax refunds and Social Security benefits; that it may file a Notice of Federal Tax Lien; and that seriously delinquent tax debt can affect your passport under the FAST Act.IRS practice · IRS LT11 / Letter 1058 guidance
Protect the hearing right first.
When a final notice is open, our first step is usually to calendar the 30-day date and, where it serves you, file a timely hearing request. That preserves the strongest protections the law offers while the right resolution is worked out, through the hearing or alongside it.Bridge's view · practitioner judgment
We take it from here.
- We take controlOnce you sign the authorization, we deal with the IRS for you. Send us any IRS letter you receive.
- Exactly where you standWhich years the notice covers, and which other years are open, from your IRS record.
- Your deadlines, risks and leverageThe hearing deadline first, then everything that depends on it.
- Your Resolution RoadmapIn writing: where you stand, what happens if nothing is done, and which paths are open to you.
Primary sources: Internal Revenue Code §6330 and §6331; Treasury Regulation §301.6330-1; IRS, Understanding your LT11 notice or Letter 1058. General information, not advice for your situation.