Letter 3193

Notice details

Notice code

Letter 3193

Category

Appeals and collection due process

Severity tier

Tier 4 — Escalation warranted. The notice involves collection enforcement, appeals rights, or significant penalty exposure.

Governing law

§6320; §6330 (Internal Revenue Code sections)

Statutory response window

30-day window — always confirm the exact deadline against the date printed on your notice.

Escalation flag

This notice carries a forfeitable right, a hard statutory deadline, or criminal-preparer risk. It is flagged for escalation in the TaxRiskOS workflow.

Source

IRS Taxpayer Advocate Service

What this notice is

The IRS Independent Office of Appeals (Appeals) issued this letter to advise you of its final determination of your Collection Due Process (CDP) hearing that you filed in response to a proposed levy action and/o r the filing of the notice of federal tax lien (NFTL). The Letter 3193 also provides the right to petition the United States Tax Court and the timeframe in which to do so. This letter is issued at the conclusion of your Collection Due Process (CDP) hearing.

Source: IRS Taxpayer Advocate Service. Reproduced for reference. General information — not legal or tax advice.

What the IRS says to do

If you have questions, you can contact the person shown at the top of the letter. You can petition the U.S. Tax Court for judicial review of Appeals’ determination on your case within 30 days from the date of the Letter 3193. This deadline cannot be extended. If your petition is not timely received, or you choose not to petition the Tax Court, your case will be returned to Collection. T o f i l e a p e t i t i o n w i t h t h e U n i t e d S t a t e s T a x C o u r t y o u c a n d o w n l o a d a f i l l a b l e p e t i t i o n f o r m a n d g e t i n f o r m a t i o n a b o u t fi l i n g a t u s t a x c o u r t . g o v . T h e T a x C o u r t e n c o u r a g e s p e t i t i o n e r s t o e

This is the IRS’s own guidance reproduced from the IRS notice page. It describes the IRS’s process — it is not legal or tax advice from TaxRiskOS.

Governing IRS procedure (Internal Revenue Manual)

The IRS’s own internal procedures for handling this notice type are documented in the Internal Revenue Manual:

• IRM 5.1.9 — 5.1.9 Collection Appeal Rights
• IRM 5.19.8 — 5.19.8 Collection Appeal Rights
• IRM 5.12.6 — 5.12.6 Appeals Processes Involving Liens

Reference to published IRS procedure. General information — not legal or tax advice.

Official IRS reference

Read the official notice page on IRS.gov: https://www.taxpayeradvocate.irs.gov/notices/letter-3193/

Related tools

TaxRiskOS is workflow software for practitioners — it captures the notice, computes the deadline, surfaces the escalation tier, and builds a document checklist. It documents process; it does not give advice or draft responses.

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