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Home > Notices > Letter 3193
Published:   |   Last Updated: October 23, 2024

Letter 3193,

Notice of Determination Concerning Collection Actions Under Sections 6320 and 6330 of the Internal Revenue Code

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Overview

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 the notice of federal tax lien (NFTL). The Letter 3193 also provides the right to petition the United States Tax Court and the timeframe in which to do so. This letter is issued at the conclusion of your Collection Due Process (CDP) hearing.

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What does this mean to me?

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 with the appeals determination. If you want to dispute the 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 is returned to Collection for further enforcement action or case resolution.

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How did I get here?

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.

You now have the right to petition Tax Court to dispute the determination by Appeals if you are within 30 days from the date of the notice.

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What are my next steps?

If you have questions, you can contact the person shown at the top of the letter. 

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. 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.

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

When your case is returned to Collection you may want to review information regarding enforcement actions: 

If you cannot pay the tax due in full, you may want to consider a collection alternative or temporary relief from collection actions, if applicable: 

 

Where can I get additional help?

Publication 4227

Overview of the Appeals Process Brochure 

Download

Publication 1660

Collection Appeal Rights 

Download

Publication 594

The IRS Collection Process 

Download

General Resources

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The Taxpayer Advocate Service is an independent organization within the IRS. TAS helps taxpayers resolve problems with the IRS, makes administrative and legislative recommendations to prevent or correct the problems, and protects taxpayer rights. TAS helps all taxpayers (and their representatives), including individuals, businesses, and exempt organizations. You may be eligible for free TAS help if your IRS problem is causing financial difficulty, if you’ve tried and been unable to resolve your issue with the IRS, or if you believe an IRS system, process, or procedure just isn’t working as it should.

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Low Income Taxpayer Clinics (LITCs) assist individuals whose income is below a certain level who need to resolve tax problems with the IRS. They also provide education, outreach, and information on taxpayer rights to individuals who speak English as a second language. LITCs represent taxpayers in disputes before the IRS and courts and help taxpayers respond to IRS notices and correct account problems. Services are offered for free or a small fee. LITCs are independent from the IRS and TAS. For more information or to find an LITC near you, see the LITC Page or Publication 4134, Low Income Taxpayer Clinic List. You can also request Pub. 4134 by calling 800-TAX-FORM (800-829-3676).

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