Most IRS letters are routine. A few start clocks that cannot be restarted. The first thing to do with any IRS letter is find the notice number (top or bottom right corner, such as CP2000 or LT11) and the response date. Here is what clients ask us most once they have that letter in hand.
Which letters are the most urgent?
- Notice of deficiency (often Letter 3219 or a CP3219A): this is the “90-day letter.” It is your ticket to Tax Court.
- Notice of intent to levy and of your right to a hearing (LT11 or Letter 1058) and the notice of federal tax lien filing (Letter 3172): these start a 30-day window to request a collection due process hearing.
- Penalty notices for international information returns, such as for a late Form 5471, 5472 or 3520: the amounts are large and the response options are narrow.
What is a CP2000?
It is not an audit. A computer compared your return with the information returns the IRS received (W-2s, 1099s, brokerage statements) and found a mismatch. It proposes changes and asks you to agree or explain, usually within about 30 days. If the IRS is right, sign and pay or set up a payment plan. If it is wrong — for example, it counted the gross sale price of stock without your cost basis — send a clear explanation with documents. If you do not respond, the next step is usually a notice of deficiency.
How does an audit work?
A correspondence audit is done by mail and usually covers one or two items. A field audit involves an agent and often several years or a business. Either way, answer only what is asked, organize your records by issue, and keep copies of everything you send. You can have a representative deal with the IRS for you using Form 2848; in most cases you do not need to attend meetings yourself.
The audit ended with a “30-day letter.” What now?
It proposes adjustments and gives you about 30 days to agree or file a protest asking for review by the IRS Independent Office of Appeals. Appeals can weigh the hazards of litigation, which an examiner cannot, so many cases settle there. If you do nothing, a notice of deficiency follows.
What does the 90-day letter mean, and can I miss it?
Under §6213(a), you have 90 days from the date of the notice (150 days if it is addressed to you outside the United States) to file a petition in the U.S. Tax Court. The last day to file is printed on the notice. Within that window, you can dispute the tax without paying it first. Miss it, and the IRS can assess, and generally your only route is to pay and sue for a refund. Courts have disagreed recently about whether a late petition can ever be saved; do not plan around that. Calendar the date the day the letter arrives.
Is Tax Court expensive?
It can be simpler than people expect. The filing fee is $60. If the amount in dispute (including penalties) is $50,000 or less for each year, you can elect the small tax case procedure under §7463, which is more informal but cannot be appealed. Most docketed cases are sent to Appeals and settle before trial.
What is a collection due process hearing?
When the IRS files a lien or plans to levy, it must notify you of your right to a hearing (§§6320, 6330). If you request it within 30 days on Form 12153, Appeals reviews the collection action and can consider alternatives such as an installment agreement, an offer in compromise or currently-not-collectible status. You can also go to Tax Court if you disagree with the result. Missing the 30 days leaves only a more limited “equivalent hearing,” which must be requested within one year and cannot be taken to Tax Court.
How far back can the IRS go?
- Assessment: generally three years after the return was filed (§6501(a)).
- Six years if you left out more than 25% of gross income, or more than $5,000 of income from foreign financial assets (§6501(e)).
- No limit for a fraudulent return or no return at all (§6501(c)).
- Open years if certain international information returns, such as Forms 3520, 5471, 5472 or 8938, were not filed. The period for the whole return generally stays open until three years after the missing form is filed (§6501(c)(8)).
- Collection: generally ten years after assessment (§6502).
Can I get penalties removed?
Often. First-time abatement can remove failure-to-file and failure-to-pay penalties if your record was clean for the prior three years. Reasonable cause can apply if you acted with ordinary care and prudence; serious illness, natural disaster or reliance on substantive advice from a competent adviser who had the full facts can qualify. Relying on someone else to file on time is generally not enough (United States v. Boyle, 469 U.S. 241 (1985)).
I cannot afford to pay. What are my options?
An installment agreement, an offer in compromise if you truly cannot pay the full amount within the collection period, or a temporary hold on collection if paying would leave you unable to meet basic living expenses. The IRS will look at your income, expenses and assets, so be prepared to document them. Keep filing current returns; most relief requires it.
When should I get help?
When the letter is a notice of deficiency, a levy or lien notice, an international penalty, a field audit, or anything involving possible fraud. Earlier is better: options narrow as deadlines pass.
Should I call the IRS or write?
For simple matters, such as confirming a payment, a call can work. For anything you may need to prove later, respond in writing by the deadline, keep a copy, and send it by a method that shows delivery, such as certified mail or the IRS’s online document upload tool when the notice offers it. Note the name and ID number of anyone you speak with.
What if the notice is for a deceased parent or a closed business?
It still needs an answer. The executor or administrator can respond for a deceased taxpayer after filing Form 56 to notify the IRS of the fiduciary relationship. For a closed business, the owners or officers may still be responsible for unpaid payroll taxes. Ignoring the notice does not make the liability go away.
Can someone else talk to the IRS for me?
Yes. An attorney, CPA or enrolled agent can represent you with a signed Form 2848 power of attorney. Form 8821 only lets someone receive your information, not act for you. Once a representative is in place, the IRS should contact the representative, and in most cases you will not need to attend meetings yourself.
Sources: 26 U.S.C. §§6213, 6320, 6330, 6501, 6502, 7463; IRS Publication 5 (Appeals) and Publication 594 (Collection); United States v. Boyle, 469 U.S. 241 (1985). As of November 2026.
