IRS LT11 or Letter 1058: Final Notice of Intent to Levy

CP504 compared with LT11 or Letter 1058

These notices can appear at different stages of the IRS collection process. The notice number, printed date, tax periods, enclosures, and appeal instructions determine the available response. The comparison below is a screening tool, not a substitute for reading the taxpayer's correspondence.

Protect the hearing-request deadline

Locate the deadline stated on the notice and calendar it immediately. Use the submission address or other method shown on the actual letter. Keep a complete copy of the request and reliable proof of timely mailing or delivery.

Form 12153 asks for the taxpayer, tax periods, type of collection action, requested collection alternative or other issue, and an explanation. Review the current form and instructions before submitting it. A public contact form is not an IRS filing channel and does not preserve a hearing deadline.

Reconcile the liability and current compliance

Compare the notice with filed returns, IRS account transcripts, payment confirmations, prior adjustments, and any existing collection arrangement. Identify whether the dispute concerns the amount assessed, a missing or misapplied payment, a return that was not filed, or the ability to pay.

IRS Appeals guidance explains that filing compliance and current payment obligations can affect consideration of collection alternatives. Inventory any unfiled returns and current estimated-tax or payroll obligations rather than reviewing only the older balance.

Issues that may be raised in a Collection Due Process request

Depending on the facts and procedural history, a taxpayer may raise collection alternatives, spousal defenses, collection-procedure issues, challenges to the appropriateness of the collection action, and in limited circumstances the underlying liability. The right to dispute the liability can depend on whether the taxpayer previously received a statutory notice of deficiency or otherwise had an opportunity to contest it.

A collection alternative is not automatically available or accepted. Eligibility, financial information, filing compliance, payment history, secured interests, and the collection statute can affect the review. State or other federal liabilities may also need separate attention.

What happens after a timely request

The IRS sends the case to Appeals for an independent review when the request qualifies. The Appeals process generally considers whether legal and administrative requirements were followed, the issues properly raised by the taxpayer, and whether the proposed collection action balances efficient collection with the taxpayer's legitimate concerns.

IRS CDP guidance describes restrictions on levy action and consequences for the collection limitations period while a timely hearing and related court review are pending, but exceptions and procedural limits apply. Confirm the status of the actual account instead of assuming collection activity has stopped.

LT11 and Letter 1058 response checklist

• The complete LT11 or Letter 1058 and every enclosure
• The hearing-request deadline, submission address, and delivery instructions
• Form 12153 and a copy of any request already sent
• Filed returns, amendments, and IRS account transcripts for each listed period
• Payment confirmations, cancelled checks, and prior collection correspondence
• Existing installment-agreement, offer, lien, levy, or appeal records
• Current filing status and current-year estimated-tax or payroll-payment records
• Financial information relevant to any collection alternative being considered

When CPA or legal help may be useful

A professional review can help organize the facts and calculations, but it cannot guarantee an IRS decision, penalty result, payment arrangement, appeal outcome, or litigation result. Depending on the agreed scope, support may include:

• Identify the tax periods, procedural stage, and printed hearing deadline
• Reconcile the assessed balance, payments, returns, and prior notices
• Organize Form 12153 and the issues supported by available records
• Review collection alternatives and compliance requirements that may fit the documented facts
• Communicate with the IRS or Appeals when representation is authorized and included in the engagement
• Identify when a tax attorney or other specialist should be considered