The IRS Independent Office of Appeals (Appeals) issued this letter to advise you of its final determination of your Collection Due Process (CDP) hearing that you filed in response to a proposed levy action and/or the filing of a notice of federal tax lien (NFTL). The Letter 3193 also provides the right to petition the United States Tax Court and the time frame in which to do so. This letter is issued at the conclusion of your CDP hearing.
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What does this mean to me?
This letter advises you of Appeals’ determination on your case and grants you the right to petition the Tax Court for judicial review if you disagree with Appeals’ determination. If you want to dispute Appeals’ determination in court, you must file a petition with the United States Tax Court within 30 days from the date of the letter. If you do not timely petition the tax court, your case will be returned to Collection.
How did I get here?
You timely filed a CDP hearing request to appeal the IRS’s intent to levy or notice of federal tax lien filing. A hearing was conducted by the Appeals Employee and a determination was made on the case.
What are my next steps?
You can petition the U.S. Tax Court for judicial review of Appeals’ determination on your case within 30 days from the date of the Letter 3193. The time you have to file a petition with the Tax Court is set by law and can’t be extended or suspended, even for reasonable cause. The IRS or TAS can’t change the allowable time for filing a petition with the Tax Court. If your petition is not timely received, or you choose not to petition the Tax Court, your case will be returned to Collection.
To file a petition with the United States Tax Court you can download a fillable petition form and get information about filing at ustaxcourt.gov. The Tax Court encourages petitioners to electronically file petitions. You can eFile your completed petition by following the instructions and user guides available on the Tax Court website at ustaxcourt.gov/dawson.html. You will need to register for a DAWSON account to do so. Or you may send the completed petition to:
United States Tax Court
400 Second Street, NW
Washington, DC 2021