IRS Notice CP90 / CP297
Final Notice of Intent to Levy & Right to Hearing
CP90 (individuals) and CP297 (businesses) are the IRS's statutory Final Notice of Intent to Levy. After 30 days the IRS can legally seize wages, bank accounts, retirement funds, and Social Security payments.
Tax Attorney · Villanova University School of Law · Admitted in Delaware, New Jersey, United States Tax Court
What Happens If You Ignore Notice CP90 / CP297
Wage garnishment, bank levy, Social Security levy, and seizure of other federal payments. If you miss the 30-day Collection Due Process window, you lose the right to Tax Court review of the levy.
Every day you wait, penalties compound, interest accrues, and your options shrink. The IRS does not negotiate well with silence — they escalate.
What You Should Do Right Now
File Form 12153 (Request for a Collection Due Process Hearing) within 30 days. This immediately stops the levy and forces the IRS to consider alternatives — installment agreement, OIC, currently not collectible, or innocent spouse relief.
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Do not call the IRS phone number on the notice until you've spoken with an attorney — anything you say can be used against you.
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Gather every page of the notice plus any prior IRS correspondence about the same tax year.
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Call a senior tax attorney (not just any CPA or preparer) so attorney-client privilege protects the conversation.
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Respond before the deadline — even a properly filed request for an extension or hearing buys you protection.
Why a Tax Attorney — Not a "Tax Relief" Company
Your conversations are legally protected. CPAs and enrolled agents do not have this protection in criminal or sensitive matters.
Our attorneys have negotiated thousands of cases. We know which IRS agents to call and what arguments actually work.
Properly filed responses can immediately pause levies, garnishments, and asset seizures while we negotiate.
If your case escalates to Tax Court, U.S. District Court, or criminal exposure, we can represent you there. Most firms cannot.
Costly Mistakes People Make With Notice CP90 / CP297
Assuming it's a mistake and throwing it away — the IRS computers move on whether you respond or not.
Paying the amount listed without verifying it — the IRS is wrong more often than people realize.
Calling the IRS without preparation and admitting facts that worsen the case.
Signing a payment agreement that locks in penalties you could have abated.
IRS Notices Related to CP90 / CP297
These are the notices the IRS most often sends before, after, or alongside a CP90 / CP297. Read the related ones to understand where you are in the collection sequence.
Tax Resolution Services That Resolve a CP90 / CP297
Senior tax attorneys at McCauley Law Offices use these strategies to stop, settle, or unwind a CP90 / CP297 notice.
Stop the IRS from seizing funds from your bank accounts.
Stop IRS wage levies that are taking money from your paycheck.
Challenge unfavorable IRS decisions through the independent Appeals Office.
Prevent the IRS from seizing your home, car, or business assets.
Relief from joint tax liability caused by your spouse's errors or fraud.
Primary Sources & Authority
We cite the underlying IRS publications and statutes so you can verify everything on this page.