Q: If the TP denies tax liability, does the IRS always send a final notice-right to hearing notice after the CP-504?
A: In the usual course, the IRS automated collection system [ACS] will issue either a CP90 or LT11 Final notice of intent to levy with a notice of your right to a collection due process hearing within about 5 weeks after issuance of the CP504.
However, I have encountered several situations whereby the final notice does not issue within the predictable time frame. This usually occurs when the account is being transferred from ACS to a local revenue officer.
It would be in your best interest to engage the services of a skilled tax attorney to assist you in navigating through the collection mine field.
Frank Huerta Jr agrees with this answer
A: To further elaborate Mr. Greenberg's response, the notice you were sent was for collections related activity. If you are still disputing the underlying tax liability you should also seek a tax attorney to determine whether you are eligible for an audit reconsideration or could file an Offer In Compromise Doubt as to Liability.
Justia Ask a Lawyer is a forum for consumers to get answers to basic legal questions. Any information sent through Justia Ask a Lawyer is not secure and is done so on a non-confidential basis only.
The use of this website to ask questions or receive answers does not create an attorney–client relationship between you and Justia, or between you and any attorney who receives your information or responds to your questions, nor is it intended to create such a relationship. Additionally, no responses on this forum constitute legal advice, which must be tailored to the specific circumstances of each case. You should not act upon information provided in Justia Ask a Lawyer without seeking professional counsel from an attorney admitted or authorized to practice in your jurisdiction. Justia assumes no responsibility to any person who relies on information contained on or received through this site and disclaims all liability in respect to such information.
Justia cannot guarantee that the information on this website (including any legal information provided by an attorney through this service) is accurate, complete, or up-to-date. While we intend to make every attempt to keep the information on this site current, the owners of and contributors to this site make no claims, promises or guarantees about the accuracy, completeness or adequacy of the information contained in or linked to from this site.