Q: If the TP denies tax liability, does the IRS always send a final notice-right to hearing notice after the CP-504?
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.
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