IRS LT11: the final levy notice and the Collection Due Process window.
LT11 (and its Automated Collection System twin, Letter 1058) is the notice that unlocks bank levy and wage garnishment authority. It also unlocks the last meaningful appeal right in the collection process.
What LT11 actually authorizes.
LT11 (Final Notice of Intent to Levy and Notice of Your Right to a Hearing) is issued by the Automated Collection System. Letter 1058 is the equivalent from a Revenue Officer. Both grant the IRS statutory authority to levy bank accounts, wages, receivables, and other property 30 days after issuance — unless a Collection Due Process request is filed inside that window.
The Collection Due Process window.
Form 12153 (Request for a Collection Due Process or Equivalent Hearing) filed inside 30 days of the LT11 date does three things: it stops the levy from executing, moves the case to the IRS Office of Appeals, and preserves the right to petition Tax Court from the Appeals determination.
Filed after day 30, the request converts to an Equivalent Hearing. The levy protection remains during the hearing, but Tax Court petition rights are lost. That difference matters when the underlying assessment is disputed or a specific collection alternative is being sought.
What the Appeals hearing actually resolves.
- The appropriateness of the proposed collection action (levy or lien).
- Collection alternatives — installment agreement, Currently Not Collectible, Offer in Compromise, or full payment.
- Spousal defenses, including innocent spouse relief where applicable.
- The underlying assessment itself, but only when the taxpayer did not receive an earlier opportunity to dispute it (rare but decisive when it applies).
The mistakes we see most often.
Filing Form 12153 without the collection alternative attached. The hearing is the forum where the alternative is decided. Arriving without one wastes the hearing.
Treating LT11 as a settlement negotiation. It is a statutory rights window. The leverage is procedural — file inside 30 days, arrive with a documented alternative, negotiate from there.
Confusing LT11 with LT1058-A (the Notice of Federal Tax Lien filing notice). LT1058-A grants a separate Collection Due Process right on the lien filing, with its own 30-day window running from a different date.
Questions we get on this one.
- Does filing Form 12153 stop a bank levy?
- Yes — provided it is filed inside 30 days of the LT11 date and covers the same tax periods listed on the notice. The levy remains stayed until the Collection Due Process hearing is concluded (typically 90 to 180 days) and, if petitioned, through the Tax Court process.
- What happens if I miss the 30-day window?
- The request converts to an Equivalent Hearing under Form 12153. Levy protection still applies during the hearing, but Tax Court petition rights are lost. In practice, the Equivalent Hearing still resolves most collection alternative disputes without going to court.
- Can I request a Collection Due Process hearing on penalty only?
- Yes. The hearing can address the appropriateness of collection on any specific portion of the balance, including penalty. Reasonable-cause and First-Time Abatement arguments are routinely raised at the hearing.
- Should I still work with the Revenue Officer while the CDP is pending?
- Yes. Filing Form 12153 does not end the Revenue Officer's authority — it moves the collection dispute to Appeals. A working relationship with the Revenue Officer on unrelated compliance matters (current-year deposits, filed returns) materially improves the Appeals outcome.
The last real appeal in the collection process.
We file Form 12153 the same week — with the collection alternative attached and the hearing strategy documented.