What Is an IRS CP504 Notice, and What Should You Do Next?

What the Letter Says Versus What It Does

The heading on a CP504 reads Notice of Intent to Levy, the first paragraph cites the levy statute, and the notice gives you 30 days. Read as a whole, the letter says something narrower than its heading. If the balance is not paid within 30 days of the notice date, the IRS can levy your state tax refund. For most other property, the notice says the IRS will send a separate letter first, one that offers a collection due process hearing, unless it has already sent one for that tax period.

So a CP504 does four things.

1. The notice satisfies the written warning the law requires at least 30 days before any levy.
2. The notice authorizes a levy on a state tax refund after 30 days, and the hearing for that levy comes only after the refund is taken.
3. The notice raises the failure-to-pay penalty from half a percent a month to a full percent a month, for months beginning after the tenth day following the notice date.
4. The notice tells you the IRS will begin looking for other assets to levy, which describes what happens next rather than a levy in itself.

What a CP504 does not do is the part that decides your next month. The notice confers no collection due process rights, starts no Form 12153 clock, and authorizes no levy on wages, a bank account, receivables or real property. A levy on any of those needs the Final Notice first. The appeal a CP504 offers is a different program, the Collection Appeals Program on Form 9423, filed within 30 days of the notice date, and the notice itself says that program is different from collection due process. A CAP appeal cannot contest the amount you owe and has no court behind it. Because a CP504 is not a collection due process notice, it also leaves the ten-year collection clock running and produces nothing a court can review.

The confusion is built into the paperwork. The Taxpayer Advocate Service's own CP504 page describes the notice as also referred to as the Final Notice, and the heading printed on the notice reads Notice of intent to seize (levy) your property or rights to property. The Advocate's page is accurate about what the notice does. The label is loose, and a reader who relies on the label will not know which clock is running. The notice that carries the hearing rights says Notice of Your Right to a Hearing on its face, and nothing else does.

The Ladder a CP504 Sits On

A CP504 is the fourth letter in a sequence that starts the day a balance is assessed, and the sequence runs over a period of months. The first bill is the CP14, the notice and demand the law requires within 60 days of assessment, and the half-percent late-payment penalty attaches if the balance is not paid within 21 days of it (10 business days where the amount is $100,000 or more). Two reminders follow, the CP501 and the CP503, and both warn about a federal tax lien rather than a levy. Neither reminder carries a deadline that costs you a right. Then comes the CP504, and after it the Final Notice.

Missing the first three letters costs money and moves the account down the track, and nothing is forfeited. Missing the CP504 costs the state refund and the higher penalty rate, makes a lien filing likely, and moves the account to the stage that produces the Final Notice. Missing the Final Notice costs the levy hold, the suspension of the collection clock and the Tax Court, which is why the collection due process hearing guide treats that letter, and not this one, as the deadline.

The State Refund Levy, and Why It Reaches Less in Florida

The one levy a CP504 authorizes on its own is a levy on a state tax refund, and the law lets the IRS take that refund before any hearing. The hearing for a state refund levy comes within a reasonable period after the levy, which means the money is gone when the hearing arrives. The carve-out is why the CP504 can call itself a levy notice and still confer no pre-levy hearing.

Florida has no personal income tax, so an individual who lives and files here has no Florida income tax refund for a CP504 levy to reach. A person who also files a return in another state, or a business with a state tax refund due, is in a different position, and the question at the consult is whether any state refund exists at all. For most Florida individuals the CP504's own levy has nothing to take.

The notice still does in Florida what it does everywhere else. The late-payment penalty doubles after the tenth day following the notice date, the IRS begins looking for other assets, and a federal tax lien filing becomes likely. The notice also names two other levies that do not wait for a hearing, the Disqualified Employment Tax Levy and the Federal Contractor Levy. Both levies reach a narrow set of employment-tax and federal-contract situations, and if either describes you, say so at the consult, because the general rule about waiting for a Final Notice may not hold for you.

A CP504 also carries a passport warning. The 2026 threshold for a seriously delinquent tax debt is $66,000, and certification to the State Department requires more than a CP504. The debt has to be assessed and over the threshold, and either a federal tax lien has been filed with the lien hearing rights lapsed, or a levy has been issued. So the warning on the notice describes a stage further down the ladder, and a payment plan being paid on time or a pending collection due process request keeps the debt outside that definition.

What to Do Before the Final Notice Arrives

The CP504 gives you a window, and the window is for getting the facts before the letter with the real deadline shows up. The order is the same in every case.

1. Pull the account transcript. An IRS Online Account shows the balance by period, and an account transcript can also be requested on Form 4506-T or through the automated line at 800-908-9946. The transcript is where the assessment date for each period sits, and the ten-year collection deadline for each period is computed from that date.
2. Verify the balance against the transcript. A CP504 states one total. The transcript shows every period, every assessment and every penalty behind that total, and a balance built from an assessable penalty rather than from a return you filed is a different problem from a balance you agree with.
3. Choose the route. There are five, and the transcript decides which one fits. Full payment stops the penalty and interest from growing and ends the sequence. An installment agreement stops any levy while it is in effect, and a pending request suspends the ten-year collection clock, plus 30 days if the request is rejected. Currently not collectible status is for the account where there is genuinely nothing to take. An offer in compromise is decided by your reasonable collection potential rather than by your sense of fairness, our offer in compromise calculator works out that number, and a pending offer also suspends the collection clock, plus 30 days if it is rejected. The fifth route is a dispute about the amount itself, covered below.

Two kinds of balance have their own pages. A penalty for a late foreign-gift, foreign-trust or foreign-company form arrives on a CP15 and is often still open to challenge, and the CP15 notice guide covers that fight. A balance for a business's withheld payroll tax can reach the owner personally as a trust fund recovery penalty, and the trust fund recovery penalty guide explains how that works and what the owner's own notice looks like.

What Not to Do With a CP504

Do not ignore it. Nothing about a CP504 forfeits a hearing right, and everything about it makes the debt more expensive. The state refund goes after 30 days, the penalty rate doubles after 10, a lien filing becomes likely, and the Final Notice moves closer while the transcript still has not been pulled.

Do not mail a Form 12153 in answer to it and assume you are protected. The form answers a collection due process notice, and no such notice has issued yet, so the request has nothing to attach to. The 30 days that count are counted from the Final Notice, and the form has to be filed inside those days, to the address on that notice for requesting a hearing.

Do not call the number on a letter you have not verified. A letter that looks like an IRS notice and pushes you toward a phone number or a payment link deserves the same caution as a stranger at the door. Sign in to your IRS Online Account and confirm that the balance and the notice exist there before you call anyone. A real CP504 matches the account, period for period.

Do not send money to anyone but the United States Treasury. A payment on a federal tax balance goes to the Treasury and nowhere else. Nobody who asks for a gift card, a wire to an individual, or a fee to a company to stop the levy today is the IRS, and money sent that way does not come back.

The Ten-Year Clock Behind the Balance

The IRS generally has ten years from the date it assessed a tax to collect it, and each period on the transcript has its own date. A CP504 does not stop that clock, a timely collection due process request does, and the hub's section on the ten-year clock explains when a hearing costs more time than it buys.

The Final Notice and the 30 Days That Count

The notice that carries the hearing rights arrives as an LT11, a Letter 1058 or a CP90, and its face says Notice of Your Right to a Hearing. The IRS sends it by certified or registered mail to your last known address at least 30 days before the first levy. The 30 days to file Form 12153 begin the day after the date printed on the notice, so a notice dated January 23 carries a request due February 22, which is the arithmetic on the IRS's own sample. A timely request holds the levy, suspends the collection clock, and preserves a petition to the United States Tax Court from whatever Appeals decides. Mail the form to the address on the notice for requesting a hearing, keep proof of the postmark, and know that a timely request that is missing something can be perfected and still counts from its original date.

CP504 sits in the middle of a ladder, and knowing which rung you are on decides what rights you still have. The notice that actually carries Collection Due Process rights is the final notice of intent to levy, and the one that puts a public encumbrance on everything you own is the notice of federal tax lien. If the balance grows past the statutory threshold, passport certification becomes a separate problem on the same debt.

Two Supreme Court decisions shape what the hearing is good for. The Court held in 2022, in Boechler, that the separate 30 days to petition the Tax Court after a determination can be extended where a diligent taxpayer was stopped by extraordinary circumstances, and that holding reaches only that petition deadline. In June 2025, in Commissioner v. Zuch, the Court held that the Tax Court loses jurisdiction over a collection due process case once the IRS stops pursuing the levy, which makes the hearing a strong tool for stopping a levy and an unreliable one for litigating how much is owed. The full mechanics, including how a lien notice is counted differently, the equivalent hearing for a late request, and what Appeals can and cannot do, are on the collection due process hearing page.

If the Balance Is Wrong

A CP504 is a collection notice, and the appeal it offers cannot reach the amount. The Collection Appeals Program decides whether the collection action should proceed, and under the IRS's own publications it does not hear a challenge to the existence or amount of the liability and its decision cannot be taken to court. So a wrong balance is never fixed by answering the CP504.

Whether you can contest the amount at the collection due process hearing depends on whether you had a chance to contest it earlier. The law allows the challenge at that hearing only if you did not receive a notice of deficiency for the liability and did not otherwise have an opportunity to dispute it. A taxpayer who let a 90-day letter expire has spent the chance. A taxpayer assessed a penalty that never carried deficiency procedures, or one whose notice of deficiency went to an address the taxpayer had left and never arrived, is often still able to raise it. Where the hearing is closed to the amount, the routes that remain are paying in full and suing for a refund, or asking the IRS to reconsider the audit, and both are slower than the hearing would have been. The rule and its exceptions are set out in the hub's section on challenging the liability.

How We Work a CP504

The order is always the same and it starts with the account rather than the notice. We pull transcripts, identify every period, compute the collection statute date for each, and confirm which notices have issued and when, because the notices tell us whether a Final Notice is already out, whether a hearing right has already been offered for a period, and whether the liability is open to challenge.

From there the work is the route and the file behind it, meaning the financial statement, the reasonable collection potential where an offer is in play, an installment agreement where the numbers support one, and the Form 12153 ready for the day the Final Notice arrives. Where Appeals reaches the wrong answer on a timely case, the petition to the Tax Court is courtroom work this firm does rather than sends elsewhere. Fees are flat and quoted once we have read the notice and the transcripts, and most of the work runs by phone and video.

Frequently Asked Questions

Common Situations

The letter read as the levy. A homeowner opens a CP504, reads Notice of Intent to Levy, and assumes the checking account freezes on day 31. The whole balance gets paid the same week with a loan against the house, without a transcript, without knowing which periods were on it, and without learning that an installment agreement would have stopped any levy while it ran. The Final Notice that actually carries the levy had not issued, and the days between the two letters were the time to find that out.

The address the notices never reached. A retiree who moved to Florida three years earlier receives a CP504 forwarded from the old address, and it is the first letter in the sequence she has seen. The CP14, the CP501 and the CP503 all went to the old house. The Final Notice will go by certified mail to the last known address the IRS has on file, which is that same old house, and its 30 days will run whether or not the mail is forwarded in time. The first step was updating the address with the IRS and pulling the transcript, so the letter that counts would arrive where it could be read.

Sources of Law

• The levy notice and the state refund carve-out. 26 U.S.C. §6331(d) (the written notice of intent to levy, given at least 30 days before the levy) and §6331(a) (authority to levy 10 days after notice and demand); §6330(f)(2) (state tax refund levies, where the hearing comes within a reasonable period after the levy), with the other carve-outs at §6330(f)(1), (f)(3) and (f)(4). The IRS sample CP504 (irs.gov/pub/notices/cp504_english.pdf) states that the IRS can levy a state tax refund after 30 days, that in most other situations a separate notice offering a collection due process hearing will follow, and that the Collection Appeals Program on Form 9423 is different from the CDP program.
• The penalty increase and the first bill. 26 U.S.C. §6651(d)(1) and (d)(2)(A) (the failure-to-pay rate rises from 0.5 percent to 1 percent per month for months beginning after the day 10 days after the §6331(d) notice); §6651(a)(3) and §6303(a) (the notice and demand within 60 days of assessment, and the 21-day payment period, 10 business days at $100,000 or more). Sample notices at irs.gov/pub/notices for CP14, CP501 and CP503.
• The Final Notice and the 30 days. 26 U.S.C. §6330(a)(2) and (a)(3)(B) (certified or registered mail to the last known address, not less than 30 days before the first levy, stating the right to request a hearing during the 30-day period); Treas. Reg. §301.6330-1(b)(1) (the period commences the day after the date of the CDP notice); IRM 8.22.5.3.1.4 (the request must be postmarked or received within that period) and IRM 8.22.5.2.5.1 (a timely but incomplete request, once perfected, relates back); IRM 8.22.4 (eff. 09-24-2025). The IRS sample CP90 (irs.gov/pub/notices/cp90_english.pdf) is dated January 23, 2019 and sets the request deadline at February 22, 2019. Requests are made on Form 12153 (Rev. 7-2022).
• What the hearing carries, and the liability rule. 26 U.S.C. §6330(e)(1) (levy and the collection period suspended while a timely hearing and any appeal are pending), §6330(d)(1) (30 days to petition the Tax Court from a determination) and §6330(c)(2)(B) (the underlying liability may be raised only where no notice of deficiency was received and no other opportunity to dispute it existed); the deficiency deadline itself, §6213(a). The Collection Appeals Program hears no challenge to the existence or amount of the liability and offers no court review, per Publication 1660 (Rev. 1-2020) and Publication 594 (Rev. 1-2026).
• The collection period and the passport. 26 U.S.C. §6502(a)(1) (ten years from assessment); the suspensions for a pending installment agreement or offer in compromise, each plus 30 days if rejected, and the Online Account, Form 4506-T and automated-line routes to the account transcript, per irs.gov/filing/time-irs-can-collect-tax. Passport certification, 26 U.S.C. §7345(b)(1) and (b)(2); the 2026 threshold of $66,000, Rev. Proc. 2025-32 §4.60, confirmed by Publication 594 (Rev. 1-2026); IRM 5.19.25 (eff. 10-10-2024).
• The two Supreme Court decisions. Boechler, P.C. v. Commissioner, 596 U.S. 199 (2022) (the §6330(d)(1) petition deadline is nonjurisdictional and subject to equitable tolling; the decision does not reach §6213(a)). Commissioner v. Zuch, No. 24-416 (U.S. June 12, 2025) (the Tax Court lacks jurisdiction under §6330 once the IRS is no longer pursuing a levy). The Taxpayer Advocate Service's CP504 page (taxpayeradvocate.irs.gov) describes the notice as also referred to as the Final Notice. (retrieved September 16, 2026)

The Letter People Read as the Levy

In 14 years of law practice, I litigate tax, business and estate disputes, and a notice read too late is where many collection cases start.

Cases with this shape keep coming up, and it is usually the same fact underneath. A CP504 is on the table, the words Notice of Intent to Levy have done their work, and the question is whether the bank account will be empty by the end of the month. No transcript has been pulled, so nobody knows how many periods are on the balance (the notice shows one total, and the transcript shows the periods behind it). I have a few take-home points.

The first is which letter counts. A CP504 reaches a state tax refund, and a Florida individual has none to take. The letter that reaches a bank account says Notice of Your Right to a Hearing, and its 30 days run from the day after its date. I read every notice in the file before I read the balance, because the notices tell me which clocks are running and the balance does not.

The second is what the gap is for. The days between a CP504 and the Final Notice are the time to pull the transcript, confirm each period and its assessment date, and pick the route, so that the Form 12153 goes out with a proposal attached rather than a plea. A hearing request that names an installment agreement, with the financial statement behind it, is a different document from one that says the taxpayer cannot pay.

Avoid paying the whole balance in a panic before the transcript is in hand. A balance that includes an assessable penalty may still be open to challenge, an old period may be close to its ten-year date, and an installment agreement stops a levy while it runs. Money paid on the strength of the CP504's heading is money paid before anyone checked what it was for.

The honest limit is that a CP504 does not say when the Final Notice will follow, and no rule I can point you to fixes the interval, so the plan cannot depend on the gap being long.

Kevin D. Klagge, Esq., admitted in Florida since 2012. Any case mentioned is a decision of a court rather than a matter handled by this firm. General information rather than advice on your situation.

Updated on September 16, 2026. Reviewed by Kevin D. Klagge, Esq., Fla. Bar No. 99502. Attorney Kevin Klagge represents families, businesses, and international clients in estate and tax planning, business structuring, and international law, with a focus on Florida legal tools. He litigates estate and business issues in court. This article is general information about federal law, not legal or tax advice, and does not create an attorney-client relationship. Collection outcomes depend on your own facts, your transcripts and IRS procedures that change. Deadlines printed on your notice control over any general description here. Past results do not guarantee a similar outcome.