IRS CP90 and CP91 Notices Explained with Transcripts Meta Title:

Receiving an IRS notice can be intimidating, especially when it arrives as a final notice regarding unpaid taxes. If several prior notices remain unresolved and an account reflects delinquent or seriously delinquent tax debt, the Internal Revenue Service (IRS) may issue a levy notice under the Internal Revenue Code. A levy can apply to wages, bank accounts, state tax refunds, Social Security benefits, vendor payments, and other property. Sometimes, even the Alaska Permanent Fund Dividend may be intercepted.

The notice must be read carefully because it explains IRS enforcement if taxes are not paid or payment arrangements are not made. A levy allows the IRS to seize assets when liabilities remain overdue, and in particular employment tax cases, a disqualified employment tax levy may apply. Taxpayers usually receive a final letter with rights to a Collection Due Process (CDP) hearing to contest the action, propose an installment agreement, or request relief based on financial hardship. Responding quickly preserves options.

This guide explains federal tax and IRS levy procedures, how levies differ from federal tax liens, and how to respond to IRS tax debt. It addresses protecting property, setting up payment options, and preparing for hearings. Whether acting alone or with professional help, the key is understanding your rights, contacting the IRS, and taking action to resolve tax liability through the most effective means.

Understanding the IRS CP90 Notice and Final Notice of Intent to Levy

CP90 and CP91 notices work differently. They give taxpayers 30 days to respond before the IRS begins levy enforcement. Each outlines the government’s authority and the taxpayer’s appeal rights.

What Is an IRS CP90 Notice: Final Notice of Intent to Levy?

A CP90 notice alerts taxpayers that the IRS intends to collect from wages, bank accounts, state tax refunds, personal property, and other assets to satisfy tax debt. Internal Revenue Code Section 6331 requires the IRS to issue this advance notice before seizing property.

• All assets may be subject to levy: The IRS can target wages, bank accounts, property, and investment accounts. The agency selects the enforcement method that maximizes recovery of unpaid taxes.
  
  
• Automated interception programs apply: Taxpayer information is placed in federal systems that intercept payments such as tax refunds and vendor payments. These programs operate continuously to enforce the collection of delinquent tax debt.

What Is an IRS CP91 Notice for Social Security Benefits?

The CP91 notice applies specifically to Social Security benefits. Under Internal Revenue Code Section 6331(h), the IRS may deduct 15% of monthly benefits to collect seriously delinquent tax debt. This levy generally applies to Old-Age and Survivors benefits, while disability benefits follow separate rules.

• Monthly deductions continue until satisfied: The IRS withholds 15% of Social Security benefits each month until the balance is paid. This ongoing reduction can make it challenging to cover essential living expenses.
  
  
• Low-income recipients have limited protection: Unlike other federal agencies, the IRS does not preserve a minimum income threshold for basic needs. Even if the levy reduces benefits below the poverty level, the IRS continues collection.

Key Differences Between CP90 and CP91

The notices target different assets and use different collection limits, but both give you the same appeal rights and deadlines.

CP90 Notice Overview

• Targeted Assets: Includes wages, bank accounts, property, and state tax refunds.
• Levy Percentage: Can be up to 100% of the asset’s value, though certain exemptions apply.
• Legal Authority: Based on Internal Revenue Code Section 6331.
• Enforcement Method: Utilizes both manual and automated collection systems.
• Appeal Rights: Taxpayers are entitled to a 30-day Collection Due Process (CDP) hearing.
• Exemption Protections: Standard exemption rules apply to protect some assets.

CP91 Notice Overview

• Targeted Assets: Limited to Social Security benefits only.
• Levy Percentage: Capped at 15% of monthly benefits.
• Legal Authority: Governed by Internal Revenue Code Section 6331(h).
• Enforcement Method: Conducted through automated systems under the Federal Payment Levy Program.
• Appeal Rights: Same CDP hearing rights as provided under CP90.
• Exemption Protections: No exemptions apply to the portion of Social Security benefits being levied.

Why the IRS Sends These Final Notice Letters

The IRS issues levy notices only after months of attempting to collect unpaid taxes through regular correspondence and phone contact. These letters represent the last step before enforcement measures such as levies or federal tax liens.

The IRS Collection Timeline and Federal Tax Lien Process

The collection process follows a structured sequence to give taxpayers multiple opportunities to resolve delinquent tax debt before enforcement. It begins with the Notice and Demand for Payment, establishing the liability. If payment is not made, the IRS sends urgent notices, each with specific deadlines and consequences.

• Multiple notices before enforcement: Taxpayers usually receive four or more collection letters before a levy notice is issued. Each letter sets a deadline and explains the actions that may follow if taxes remain unpaid.
  
  
• Legal requirement for due process: The Internal Revenue Code requires the IRS to provide notice and opportunity to respond before seizing assets. These protections allow taxpayers to request hearings, propose installment agreements, or dispute the liability before levy action begins.

Alaska Permanent Fund Dividend and Federal Tax Payment Levies

The Federal Payment Levy Program (FPLP) automatically intercepts certain federal payments before they reach taxpayers. Established in 2000, the system matches Social Security numbers with federal payment records. When a match is identified, the IRS applies the levy to collect delinquent tax debt.

• Automated levy processing ensures efficiency: Federal payments are intercepted automatically once a taxpayer’s information is in the FPLP system. This process increases enforcement consistency and ensures standardized treatment for delinquent tax debt.
  
  
• Federal payments subject to levy: The program can intercept tax refunds, Social Security benefits, federal wages, and Alaska Permanent Fund Dividend payments. Only specific payments, such as Supplemental Security Income, remain exempt from automatic levy.
  
  

Common Triggers for CP90 and CP91 Notices

The IRS generally issues CP90 and CP91 notices after prior collection efforts fail. These notices indicate that standard collection attempts have ended and enforcement is about to begin.

CP90 Triggers

A CP90 notice follows several unanswered collection letters or a defaulted installment agreement. It may also be issued when the IRS identifies undisclosed assets or income through information-matching systems.

• Broken installment agreements accelerate enforcement: When taxpayers miss payments, the IRS views it as noncompliance and quickly shifts to levy action. This can include garnishing wages, freezing bank accounts, or seizing property.
  
  
• Undisclosed assets trigger immediate enforcement: If the IRS discovers bank accounts or property not previously reported, it often interprets this as concealment. In such cases, the levy action begins rather than renewed negotiation.

CP91 Triggers

The CP91 notice is issued after the IRS confirms that a taxpayer receives Social Security benefits and is not exempt from levy. This determination is based on data shared between the IRS and the Social Security Administration.

• Data verification confirms eligibility: Automated systems match Social Security benefit records with IRS files before initiating a 15% levy. This verification ensures the IRS applies enforcement only where legally authorized under Section 6331(h).
  
  
• Income-level screening offers limited protection: IRS procedures check whether a taxpayer’s income falls under federal poverty guidelines. This review usually does not prevent levy, and 15% of monthly benefits can still be withheld.
  
  

How to Read IRS Levy Transcripts for Bank Accounts and Assets

Your IRS account transcripts often show levy-related activity before you receive an official levy notice in the mail. Recognizing these transaction codes can help you anticipate enforcement action and prepare before the IRS seizes wages, bank accounts, or other property.

Transaction Codes to Watch

• Transaction Code 971 with Action Code 170: This entry means the IRS has issued a Federal Payment Levy Program notice for your account. It confirms that your case has advanced to the stage where federal payments—such as tax refunds or Social Security benefits—are subject to levy enforcement.
  
  
• Transaction Code 580: This code identifies the types of assets the IRS plans to target through levy. By reviewing it, taxpayers and their representatives can see whether the IRS is pursuing wages, bank accounts, or other assets, which allows for timely preparation and defense.
  
  
• Transaction Code 590: This notation indicates that your account is being processed for automated levy programs. Its presence signals that enforcement may begin without further direct communication, making it an important early warning for taxpayers to act quickly.
  
  
• Early warning helps you prepare: Because these codes appear on transcripts before notices arrive by mail, reviewing them regularly allows taxpayers valuable time to seek payment arrangements or appeal rights before collection starts.

Master File Codes and What They Mean

Master File codes track the overall status of a taxpayer’s account across IRS systems. Tax professionals often rely on these codes to understand IRS priorities, predict what actions may follow, and build an appropriate response strategy.

• Codes ensure consistency across IRS systems: These tracking numbers align case information across the IRS’s databases. This coordination helps prevent conflicting enforcement actions by different IRS offices handling the same file.
  
  
• Professionals use codes strategically: Tax attorneys, CPAs, and enrolled agents interpret Master File codes to assess case complexity, anticipate timing, and negotiate with the IRS more effectively. This insight allows them to protect taxpayer rights and reduce unnecessary levy actions.
  
  

Immediate Steps After Receiving a CP90 or CP91

Step 1: Verify Notice Authenticity

Confirm the notice is legitimate by checking for proper IRS letterhead, your full Social Security number, and valid IRS contact information. Authentic notices include specific tax periods, assessed balances, and instructions for response. Because scammers often send fraudulent IRS notices, verifying these details protects taxpayers from identity theft or improper payments.

Step 2: Gather Essential Financial Documents

Collect recent bank statements, pay stubs, tax returns for the years at issue, and records of any payments already made to the IRS. These documents form the foundation of any strategy to resolve IRS tax debt through installment agreements, hardship claims, or other relief options. A well-prepared financial file also improves communication with IRS representatives and supports requests for payment arrangements.

Step 3: Calculate Your Financial Position

Determine your monthly income and essential living expenses using accurate, well-documented numbers. This calculation demonstrates how much you can realistically pay toward your delinquent tax debt each month and supports requests for installment agreements or Currently Not Collectible status. Presenting precise financial data improves the likelihood of securing favorable terms from the IRS and avoiding overly burdensome levy actions.

Your Appeal Rights and Options

You have 30 days from the notice date to request a hearing that stops collection and gives you an independent review.

Collection Due Process Hearing Explained

A CDP hearing allows an independent Appeals Officer to review your case. During the hearing, you can challenge whether the tax is valid, propose installment agreements or other payment arrangements, and raise any procedural errors. Appeals Officers can approve solutions that frontline collection staff may not accept.

• Independent review benefits taxpayers: Appeals Officers operate separately from collection staff and often approve arrangements that balance the government’s need to collect with the taxpayer’s ability to pay. This independence frequently leads to more favorable outcomes than negotiating directly with collectors.
  
  
• Multiple issues can be resolved immediately: The hearing covers the proposed levy, the underlying tax debt, and procedural matters in a single review. Addressing everything together streamlines the process and avoids the need for multiple appeals.

Using Form 12153 Correctly

Form 12153 is the official request for a CDP hearing. The form must clearly identify the actions you are disputing and propose realistic alternatives for resolution. Incomplete or vague submissions can delay review or result in denial.

• Specificity is critical: The form should outline exactly which collection actions you are disputing and why. General complaints about IRS treatment are not sufficient for meaningful consideration.
  
  
• Proposals must be practical: Suggested alternatives, such as installment agreements or other payment arrangements, should match your financial situation. Realistic proposals demonstrate good faith and increase the likelihood of approval.

Critical 30-Day Deadlines

The 30-day deadline begins on the date printed on your IRS notice—not the date you receive it. Missing this deadline by even a single day eliminates your right to a Collection Due Process (CDP) hearing and allows collection activity to move forward immediately. While you may still request an Equivalent Hearing within one year, you lose the right to petition the U.S. Tax Court if you disagree with the outcome.

• The deadline cannot be extended: The IRS does not grant extensions for any reason, including postal delays or personal emergencies. A late filing, even by one day, results in the loss of these critical protections.
  
  
• Always count from the printed notice date: The 30-day period begins on the date shown on it. Calculate your response timeline from that printed date rather than the day the notice arrives in your mailbox to avoid costly mistakes.
  
  

IRS Installment Agreement and Payment Resolution Strategies

Taxpayers who cannot pay in full have several options to resolve IRS tax debt. These arrangements can stop levy action, reduce penalties, and provide manageable repayment terms.

Full Payment Options

Paying the balance in full immediately stops collection activity and prevents further penalties and interest. The IRS accepts electronic transfers, credit or debit cards, certified checks, and money orders. Full payment also helps protect credit and professional standing from the effects of a federal tax lien.

• Full payment eliminates complications: Satisfying the balance in full ends collection stress, prevents future levy actions, and protects credit and professional licenses. For taxpayers who can afford it, this remains the most straightforward solution.
  
  
• Flexible methods are available: Payments can be made electronically for faster processing or through certified checks and money orders for formal documentation. These multiple payment methods allow taxpayers to select the most convenient option while ensuring immediate resolution of delinquent tax debt.

IRS Installment Agreement Options

When full payment is impossible, the IRS offers installment agreements for repayment over time. Debts under $10,000, payable within three years, qualify for guaranteed approval. Streamlined agreements cover debts up to $50,000 with less disclosure, while larger debts require complete financial analysis and may be eligible for partial payment arrangements.

• Guaranteed approval offers safety: Taxpayers who meet the requirements for guaranteed installment agreements get automatic approval, which stops any collection actions as long as they keep making payments. This option offers essential protection for those with smaller balances.
  
  
• Agreements can adjust to circumstances: Installment agreements may be structured to account for changes in income, seasonal fluctuations, or long-term financial conditions. The IRS considers age, health, and earning potential when determining reasonable monthly payments.

Offer in Compromise

An Offer in Compromise (OIC) allows taxpayers to resolve tax debt for less than the full amount owed. The IRS reviews these requests when full payment is unrealistic, the liability is disputed, or paying in full would cause financial hardship. An approved offer settles the debt entirely and ends collection activity.

• The IRS evaluates the full financial picture: Income, assets, and necessary living expenses are reviewed to calculate the minimum acceptable settlement. This evaluation ensures the IRS considers both the ability to pay and essential financial needs.
  
  
• Accepted offers provide lasting resolution: A successful OIC clears the outstanding balance and halts penalties and interest. This resolution affords taxpayers a fresh start and removes the pressure of ongoing IRS collection.

Currently Not Collectible Status

The Currently Not Collectible (CNC) status allows the IRS to suspend collection when payment prevents taxpayers from covering basic living expenses. It is granted in cases of genuine financial hardship. The IRS reviews these accounts periodically and may resume collection if financial circumstances improve.

• Collection pauses during financial hardship: CNC status stops most enforcement actions, including levies and seizures. This protection gives taxpayers room to stabilize essential expenses without ongoing IRS pressure.
  
  
• Periodic reviews determine eligibility: The IRS regularly evaluates CNC accounts to see if income or assets have increased enough to resume collection. To maintain this protection, taxpayers must also report significant changes in financial condition.
  
  

Avoiding Mistakes When Responding to IRS Notices

Mistakes with deadlines or procedures can remove key protections and make resolution harder. Careful attention ensures taxpayers preserve their rights.

Timing and Deadline Errors

Missing the 30-day deadline for a Collection Due Process (CDP) hearing removes the automatic hold on collection and the right to appeal in Tax Court. Deadlines run from the printed notice date, so forms should be mailed early to guarantee timely delivery.

• Deadline calculations must be accurate: Count business days and include weekends and holidays in your timeline. A one-day error eliminates important protections.
  
  
• Allow adequate time for mail delivery: Send documents with enough buffers for delivery and processing. Certified mail with return receipts provides proof of timely filing.

Procedural Missteps

Failing to respond to IRS notices allows automated collection to begin and removes chances for resolution. CP91 notices also make clear that the Social Security Administration cannot assist with levy actions. Incomplete or missing forms may result in the denial of a hearing request.

• Immediate response preserves options: Acting quickly affords the best opportunity to negotiate payment arrangements or request hearings. Delays reduce available choices.
  
  
• Contact the correct agency: Only the IRS can stop levy enforcement. The Social Security Administration has no authority to intervene, so all questions must be directed to the IRS using the contact details on the notice.
  
  

Financial Documentation Issues

Inaccurate or incomplete financial records can undermine negotiations with the IRS. Underestimating expenses can result in default payment plans, and the IRS often rejects undocumented claims. Providing inconsistent information damages credibility and complicates resolution efforts.

• Document all reasonable expenses thoroughly: Keep detailed records of housing, utilities, transportation, food, and medical costs. The IRS requires proof of claimed expenses, and undocumented claims are often denied.
  
  
• Keep your financial information consistent: Ensure income and expense figures match all IRS forms and communications. Inconsistencies may cause the IRS to question your accuracy and reduce the chances of approval.
  
  

When to Contact the IRS and Seek Professional Representation

Some situations require professional help to protect your interests and get better outcomes.

Signs You Need Professional Help

Professional assistance is recommended when tax debt exceeds $25,000, multiple tax years are involved, or prior self-help efforts have failed. Legal issues, potential criminal exposure, or disputes about whether the tax is valid also warrant representation.

• Large debts and complex cases need expertise: High-dollar balances or multi-year liabilities usually require professional guidance to secure the best resolution. Skilled representation often results in better terms that outweigh the cost of services.
  
  
• Representation reduces stress and improves outcomes: Professionals manage direct contact with the IRS while protecting taxpayer rights. This support enhances negotiation results and provides peace of mind during the process.

Types of Tax Professionals Who Can Represent You

Enrolled Agents, Certified Public Accountants, and tax attorneys all have the authority to represent taxpayers before the IRS. Depending on the complexity of the case, each offers unique advantages.

• Enrolled Agents specialize in tax representation: These professionals focus solely on tax matters and often provide cost-effective solutions for collection problems. Their expertise can lead to faster, more efficient resolutions.
  
  
• Attorneys provide privileged communication protection: Tax attorneys offer the attorney-client privilege, which is critical in complex disputes or potential criminal cases. This protection encourages full disclosure, allowing attorneys to build stronger defenses and strategies.
  
  

Action Checklist for CP90/CP91 Recipients

This timeline helps protect taxpayer rights and assets while keeping resolution options open.

Within 24 Hours

• Verify the notice is authentic: Check the IRS contact details and confirm that the notice lists accurate taxpayer information. This step prevents confusion or falling for fraudulent letters.
  
  
• Calculate your response deadline: Mark the 30-day deadline based on the printed notice date. Tracking early avoids mistakes that forfeit appeal rights.
  
  
• Secure the notice and make copies: Store the original and create copies for records or advisors. Organized documentation supports later actions.
  
  
• Gather financial records: Collect bank statements, pay stubs, and tax returns. These documents will be needed for payment plans or hearings.

Days 1–7

• Review your finances: Analyze income, expenses, and assets to see what you can afford. Realistic numbers prevent agreements that might default.
  
  
• Research resolution options: Identify whether you qualify for an installment agreement, hardship status, or settlement. Knowing choices early improves planning.
  
  
• Consider professional help: Complex or high-dollar cases benefit from representation. Professionals often improve negotiation results.
  
  
• Prepare Form 12153 if appealing: Begin filling out the form with accurate details and alternatives. Early preparation avoids last-minute errors.

Days 7–25

• Mail Form 12153 if requesting a hearing: Use certified mail with a return receipt to prove timely filing. Proof protects your rights if disputes arise.
  
  
• If paying directly, contact the IRS. Call to arrange payment or a plan if you are not requesting a hearing. Direct action may resolve the case quickly.
  
  
• Implement your resolution strategy: Implement your chosen option with supporting documents. Showing good faith increases your chances of approval.
  
  
• Confirm IRS receipt and processing: Follow up to ensure the IRS received and is acting on your submission. Verification avoids delays or misunderstandings.
  
  

Frequently Asked Questions

What is the difference between a CP90 and a CP91 notice?

A CP90 notice allows the IRS to levy wages, bank accounts, and property, with potential seizure up to 100%, subject to exemptions. A CP91 notice specifically targets Social Security benefits and limits the levy to 15% monthly. Both notices grant the same appeal rights, including 30 days to request a Collection Due Process hearing.

How much time do I have to respond to a CP90 or CP91?

You have exactly 30 days from the printed date on the notice to request a Collection Due Process hearing. The deadline does not extend to the day you receive the notice and cannot be postponed. Missing it removes automatic protection against levy enforcement and eliminates your right to petition the U.S. Tax Court.

Can the IRS be involved with my Social Security benefits?

Under Internal Revenue Code Section 6331(h), the IRS may levy 15% of Social Security Old-Age and Survivors benefits regardless of financial hardship. Unlike other agencies, the IRS does not preserve a minimum income threshold for basic needs. Supplemental Security Income is excluded, but standard Social Security benefits remain subject to monthly levy collection.

What happens during a Collection Due Process hearing?

A Collection Due Process hearing gives taxpayers an independent review by an IRS Appeals Officer. You may challenge the tax liability, propose an installment agreement, or request an Offer in Compromise. Appeals Officers are separate from collection staff and may approve alternatives that frontline collection personnel cannot authorize, including hardship status or settlement.

What payment options are available to stop an IRS levy?

Taxpayers may resolve levy threats by paying in full, entering a guaranteed installment agreement for debts under $10,000, or choosing a streamlined plan for debts up to $50,000. Larger balances may require full financial disclosure. Other relief includes the Currently Not Collectible status, which suspends collection during hardship, and Offers in Compromise, which reduces debt.

Which Social Security benefits are exempt from IRS levy?

Supplemental Security Income under Title XVI is fully exempt from levy. In addition, lump-sum death benefits and payments made to children are protected. Taxpayers at or below federal poverty guidelines may also avoid the inclusion of the Federal Payment Levy Program. However, Old-Age and Survivors benefits remain subject to the IRS’s 15% levy authority each month.

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