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Published: August 21, 2020   |   Last Updated: May 26, 2022

Letter 4380

Appeals Received Your Request for a Collection Due Process and/or Equivalent Hearing

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Letter Overview

You will receive this letter from the Independent Office of Appeals (Appeals) when you have filed a request for Collection Due Process (CDP) and/or Equivalent Hearing based on a frivolous position or with the intent to delay or impede federal tax administration.  Appeals will provide you with a 30-day deadline to either perfect the request or withdraw the request to avoid a possible penalty.  If you do not amend or withdraw the CDP and/or Equivalent Hearing, Appeals will disregard your request and return your case to Collections.

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

What does this letter mean to me?

These letters are sent to you as part of the (CDP) or Equivalent Hearing requests.  These letters are in response to your timely  completion and submission of Form 12153, Request for a Collection Due Process or Equivalent Hearing. These letters are sent when a CDP and/or Equivalent Hearing was submitted based frivolous position or a desire to delay or impede federal tax administration. Appeals is providing you with 30 days to either perfect the request or withdraw the request to avoid a possible penalty.  If you do not amend or withdraw the request forCDP and/or Equivalent Hearing, Appeals will disregard your request and return your case to Collections. A $5,000 penalty may also be assessed.

See Publication 1660, Collection Appeal Rights, for a full explanation of the CDP process.

How did I get here?

You owe tax and did not pay the liability after several attempts by the IRS to collect it.. You  timely completed and submitted Form 12153 because you did not agree with the collection efforts taken and most times, this will stop enforcement action from proceeding while a hearing or appeal is pending.

When you filed the request, you based your request on a frivolous position or a desire to delay or impede federal tax administration.

What are my next steps?

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Read the Letter

The letter will have instructions on how to respond and the date by which to respond.

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Prepare your response

You should timely respond by amending your request to include a relevant issue or withdrawing the frivolous/delaying/impeding issue from appeal. You should be prepared to explain why you disagree with the  collection action and propose a collection alternative or remedy for satisfying the tax liability or lien release. You should have substantiating documentation of any issues you wish to discuss, including proof of current income and expenses.

Where can I get additional help?

Your options

If you think you’ll have trouble paying your taxes or the Notice of Federal Tax Lien filing will cause economic hardship, it’s helpful to know what your options are to address your tax debt.

Understanding your notice or letter

Get Help topics

Browse common tax issues and situations at Get Help on the TAS website.

  • Levies on TAS website’s Get Help section
  • Liens on the Taxpayer Advocate Service (TAS) website’s Get Help section

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.

Related Letters

Letter 4837, Appeals Received Your Request for a Collection Due Process Hearing
Letter 3820, Appeals Received Your Offer in Compromise and We Can Consider It
Letter 3821, Appeals Received Your Offer in Compromise and We Cannot Process It
Letter 3846, Appeals Received Your Request for a Collection Due Process Hearing
Letter 4380, Appeals Received Your Request for a Collection Due Process Hearing
Letter 4993, Appeals Transfer Letter

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Where am I in the tax system?

Appeals is responding to your request for a Collection Due Process and/or Equivalent Hearing requesting you amend or withdraw your hearing request because your initial request contained only frivolous positions or was intended to impede or delay tax administration.

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