Notice of Determination Concerning Collection Actions Under Sections 6320 and 6330 of the Internal Revenue Code
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The Independent Office of Appeals (Appeals) reaches a determination on the IRS decision that either the collection activity is sustained or not and advises the taxpayer of the review that was conducted. It also provides the right to petition the Tax Court and the timeframe in which to do so. If the taxpayer does not petition the Tax Court, his or her case is returned to Collection for further enforcement action or case resolution. This notice is issued as a result of the decision point following the Collection Due Process (CDP) hearing.
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This letter advises you of the Appeals determination on your case and grants you the right to petition the Tax Court for judicial review of the determination, if you disagree.
You timely filed a CDP hearing request to appeal IRS’s intent to levy or notice of federal tax lien filing. A hearing was conducted by the Appeals Technical Employee and a determination was made on the case to sustain the collection action.
1. Within 30 days of IRS Letter 3193, you can petition the Tax Court for judicial review of Appeals’ determination on your case. This deadline cannot be extended. If your petition is not timely received, or you choose not to petition the Tax Court, your case will be returned to Collection.
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If you think you’ll have trouble paying your taxes or the NFTL filing will cause economic hardship, it’s helpful to know what your options are to address your tax debt.
If you disagree with Appeals’ determination, you petition the U.S. Tax Court.
The Taxpayer Advocate Service is an independent organization within the IRS that helps taxpayers and protects taxpayers’ rights. We can offer you help if your tax problem is causing a financial difficulty, you’ve tried and been unable to resolve your issue with the IRS, or you believe an IRS system, process, or procedure just isn’t working as it should. If you qualify for our assistance, which is always free, we will do everything possible to help you.
Visit www.taxpayeradvocate.irs.gov or call 1-877-777-4778.
Low Income Taxpayer Clinics (LITCs) are independent from the IRS and TAS. LITCs represent individuals whose income is below a certain level and who need to resolve tax problems with the IRS. LITCs can represent taxpayers in audits, appeals, and tax collection disputes before the IRS and in court. In addition, LITCs can provide information about taxpayer rights and responsibilities in different languages for individuals who speak English as a second language. Services are offered for free or a small fee. For more information or to find an LITC near you, see the LITC page on the TAS website or Publication 4134, Low Income Taxpayer Clinic List.