Popular search terms:
Published:   |   Last Updated: May 23, 2023

Letter 3210

Decision Letter on Equivalent Hearing Under Internal Revenue Code Sections 6320 and/or 6330

View our interactive tax map to see where you are in the tax process. It could help you navigate your way through the IRS.

Show on Roadmap
Taxpayer Roadmap with folded image in front

Letter Overview

This letter is issued to you when the IRS Independent Office of Appeals (Appeals) makes a determination on your Equivalent Hearing request.

This notice or letter may include additional topics that have not yet been covered here. Please check back frequently for updates.

What does this mean to me?

You submitted a request for a Collection Due Process (CDP) hearing. However, your request was not filed within the 30 days of the date of mailing of the CDP notice as required by Internal Revenue Code (IRC) section 6320 and/or 6330. You received an Equivalent Hearing which is  a hearing equivalent to a CDP hearing and the IRS Independent Office of Appeals (Appeals) made a decision on your appeal request. You cannot dispute Appeals in an Equivalent Hearing decision in the U.S. Tax Court. 

How did I get here?

You have a balance due on your tax account. The IRS has either issued you a CDP levy notice or filed a Notice of Federal Tax Lien (NFTL) providing CDP appeal rights. You have exercised your appeal rights and made a request for a CDP hearing after the due date for a timely hearing. You were entitled to an Equivalent Hearing with Appeals within the one-year period starting after the date of the CDP levy notice or, with respect to CDP lien cases, within the one-year period commencing the day after the end of the five-business-day period following the filing of the NFTL. Appeals made a decision on your appeal request.

What are my next steps?


If You Have Questions

If you have questions, you can contact the person shown at the top of the letter. You cannot dispute an Appeals Equivalent Hearing decision regarding the collection action (NFTL filing or levy) in the U.S. Tax Court because your appeal request was not filed within 30 days from the date of mailing of the CDP notice as required by IRC section 6320 and/or 6330.

Your account will be returned to Collection for action consistent with Appeals’ decision. You may want to review information regarding the following enforcement actions:


Payment Options


Agreed Collection Alternative

If you agreed to a collection alternative such as an installment agreement or offer in compromise, you’ll need to make payments based on your agreement with the IRS. You’ll also need to stay current in filing and paying your taxes during the time of the agreement, and if you enter into an offer in compromise, for five years after the IRS accepts your offer.


Additional Information

If you believe that you timely filed your CDP hearing request and you can provide proof of timely filing, you can file a petition with the U.S. Tax Court within 30 days from the date of this letter to dispute Appeals’ decision about the timeliness of your hearing request.

To obtain a petition form and the rules for filing a petition, you can visit the U.S. Tax Court website.

Where can I get additional help?

What are your options?

Understanding your notice or letter

Get Help topics

Browse common tax issues and situations at TAS Get Help

If you still need help

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.