This notice is different from every other letter the IRS has sent you. It starts a 30-day clock on your right to a hearing — and once it runs out, the IRS can levy your wages or bank account without further warning.
CP90 (sent to individuals) and CP297 (sent to businesses) are both titled Final Notice of Intent to Levy and Notice of Your Right to a Hearing. Unlike earlier collection notices, this one is a legal prerequisite the IRS must satisfy before it can levy your wages, bank accounts, or other property. It also opens a specific, time-limited right: a Collection Due Process (CDP) hearing.
You have 30 days from the date on the notice to file Form 12153 and request a CDP hearing. Doing so generally pauses levy action while the hearing is pending. Missing the deadline does not end your options, but it does end this specific right — including the ability to later challenge the levy in U.S. Tax Court.
A CDP hearing is handled by the IRS Independent Office of Appeals — a separate function from the collection employees who sent the notice. At the hearing, you can:
If you disagree with the Appeals determination, you generally have the right to petition U.S. Tax Court within 30 days of that decision — a right that only exists if you requested the CDP hearing on time in the first place.
You still have options, just fewer of them. You can request an "equivalent hearing" (similar review, without the Tax Court appeal rights), or move directly to negotiating an installment agreement, Offer in Compromise, or Currently Not Collectible status with the IRS Collection function. The key difference is that once the CDP window closes, the IRS is legally clear to levy while any of that is pending — which is why speed matters even more at this stage.
When a CP90 or CP297 lands, timing is everything. We confirm the notice date and deadline the same day, file Form 12153 if a CDP hearing is the right move, and negotiate directly with IRS Collection or Appeals on your behalf. If a levy has already been issued, we move immediately to get it released.
A free case review tells you exactly how much time you have left and the fastest way to stop a levy.
Get your free case reviewCP90 (for individuals) and CP297 (for businesses) are Final Notice of Intent to Levy and Notice of Your Right to a Hearing. They mean the IRS intends to seize wages, bank accounts, or other property to satisfy an unpaid tax debt, and they start a 30-day window to request a Collection Due Process hearing.
A CDP hearing is an independent review, held by the IRS Office of Appeals, where you can dispute the levy, propose a collection alternative like an installment agreement or Offer in Compromise, or in some cases challenge the underlying tax debt. Requesting one generally pauses levy action while it's pending.
File Form 12153, Request for a Collection Due Process or Equivalent Hearing, within 30 days of the date on your CP90 or CP297 notice. Missing the deadline doesn't eliminate your options entirely, but it does eliminate the formal right to a CDP hearing and the judicial appeal rights that come with it.
Not during the 30-day window if you request a CDP hearing in that time. If you let the deadline pass without responding, the IRS can proceed with levying wages, bank accounts, and other property without further notice.