LT11 and Letter 1058 are not ordinary balance-due reminders. They generally notify a taxpayer of the IRS’s intent to levy and explain the right to request a Collection Due Process, or CDP, hearing. The response date printed on the notice matters.
Why a timely CDP request matters
A timely hearing request can suspend levy action for the covered tax periods while the CDP process is pending. It also permits review by the IRS Independent Office of Appeals and can preserve the right to ask the United States Tax Court to review Appeals’ determination.
If the deadline is missed, an equivalent hearing may still be available within a limited period. An equivalent hearing can be useful, but it ordinarily does not carry the same right to Tax Court review of the hearing result. That difference can change the value of the remedy.
What Appeals may consider
- Whether legal and procedural requirements were followed.
- Appropriate collection alternatives, such as an installment agreement, currently-not-collectible status, or an offer in compromise.
- Spousal defenses or challenges to the underlying liability when the law permits them.
- Whether the proposed collection action balances efficient collection against unnecessary intrusiveness.
Do not wait to gather the account record
The notice should be compared with transcripts, prior notices, filing status, financial facts, and any pending collection proposal. Filing a hearing request preserves procedure; it does not by itself prove that a particular resolution is available.
If the deadline is close, protecting the deadline comes before perfecting every supporting document. The exact filing method and address on the notice should be followed.