What Is IRS Notice CP90?

A CP90 — Final Notice of Intent to Levy and Notice of Your Right to a Hearing — is one of the most important and urgent notices the IRS sends. It means the IRS intends to seize your property (including wages, bank accounts, and other assets) to collect an unpaid tax debt, and you have 30 days from the date of the notice to request a Collection Due Process (CDP) hearing before the levy action can proceed.

The 30-day deadline to request a CDP hearing is critical and strict. If you miss it, you lose your right to a formal CDP hearing, though you may still be eligible for an "Equivalent Hearing" that provides less protection. A timely CDP hearing request puts a hold on all IRS collection action (including levies) while the hearing is pending — this gives you time to present your case, propose an alternative resolution, or challenge the underlying liability if you've never had a prior opportunity to do so.

At a CDP hearing before the IRS Office of Appeals, you can propose collection alternatives such as an installment agreement or Offer in Compromise, argue that the levy would cause economic hardship, challenge the validity of the underlying tax assessment (if you've never had a chance to contest it), or raise other procedural issues. If Appeals rules against you, you generally have the right to petition the U.S. Tax Court to review the CDP determination — another layer of protection.

If you receive a CP90, do not ignore it and do not simply hope the problem goes away. Thirty days passes quickly, and missing the deadline eliminates your most powerful legal protection against IRS collection action. This is one of the situations where consulting a tax professional — a tax attorney, CPA, or enrolled agent experienced in IRS collections — is most valuable, since the procedural steps and strategic options at this stage are complex and the stakes are high.