King of Prussia, PA: CP504 Versus LT11 Hearing Rights

In King of Prussia, PA, the short answer is this: CP504 does not start the Collection Due Process hearing clock, but LT11 does. If preserving a response deadline matters, treat CP504 as an early warning and LT11, or L-1058, as the notice that usually carries formal hearing rights. The safest move is to review the exact notice, the mailing date, and your proof of receipt before you miss the filing window.

Why CP504 is a warning, not the hearing trigger

The IRS FAQ states that the IRS cannot levy with just CP504. CP504 is a notice that the IRS intends to levy certain assets later if the balance remains unresolved. It is serious, but it is not yet the final notice that creates the right to request a Collection Due Process hearing.

That distinction matters because the hearing right is tied to the later Notice of Intent to Levy and Notice of Your Right to a Hearing, often LT11 or L-1058. If you respond only after the levy notice arrives, you may still have hearing rights, but the response deadline is measured from that later notice, not from CP504.

A document-led case review should start by separating the notices. Look at the title at the top, the tax periods listed, any contact number, and whether the notice says it explains your right to a hearing. Do not assume every collection notice gives the same appeal rights.

What LT11 changes under IRM 5.1.9

IRM 5.1.9.3.2.1 explains that a timely CDP levy hearing request must be submitted in writing within 30 days beginning the day after the date of the CDP levy notice. That is the practical deadline that matters when LT11 is in play.

The IRS also says the request should be sent to the office and address on the notice, or delivered in another permitted way if the notice provides that option. If it is mailed to the listed address and postmarked timely, the postmark can control timeliness. Keep the envelope.

If you received only CP504, you generally do not yet have the LT11-based CDP hearing window. But once LT11 arrives, do not wait for a better time to organize records. The deadline can pass while you are still gathering documents, and a late request may change the procedure available to you.

Records that help preserve the deadline

For a timely response, gather the notice itself, the envelope, proof of the date you received it, and any IRS account transcript that shows the collection module history. If you have both spouses on a joint liability, note that each spouse may receive a separately addressed notice in a separate envelope.

If you plan to request a CDP hearing, use Form 12153 and state clearly why you disagree with the collection action. The IRS source says the request should include the reasons for disagreement and the taxpayer’s signature or authorized representative’s signature. If you want to discuss payment alternatives, be ready to provide financial information, because Appeals may need enough detail to evaluate collection alternatives.

A hypothetical example: if a taxpayer receives CP504 first and later LT11, the taxpayer should not wait until the second notice is nearly expired to decide whether the balance is wrong or whether they need a collection alternative. The earlier notice is the cue to start the file, and the later notice is the one that can set the hearing deadline.

Practical next step before the window closes

Read the notice date, the file-by language, and the address where the request must go. Then compare the notice to your account records and prepare a written request that fits the notice you actually received. If the levy notice has already arrived, the goal is to preserve the deadline first and argue the merits second.

If you are unsure whether your notice is CP504 or LT11, or whether the request was sent on time, a focused case review can help you organize the paper trail before you lose options. That review should be document-based, not assumption-based, because the appeal right depends on the exact notice and timing.

Important limit: a CDP hearing can open the door to review collection alternatives and, in limited situations, the underlying tax issue. But filing a request does not erase the debt, and it does not guarantee the IRS will stop collection forever. The notice type and the filing date still control what rights you have.

Questions about CP504 versus LT11: which notice gives hearing rights?

Sources and related resources

• Internal Revenue Manual 5.1.9
• Collection due process (CDP) FAQs

Tax.Directory IRS guidance and FAQs · IRSDecoder notice explanations · ETSVideos

General educational guidance. Relief and collection protections depend on the actual notices, account history, financial evidence, and applicable law. A consultation does not itself stop enforcement or preserve an appeal deadline.