IRS NOTICE REFERENCE
Letter 3846
You will receive this letter from Appeals when you have filed a request for Collection Due Process (CDP) and/or Equivalent hearing (EH) request. This is the first step in the appeals process, informing you about a confer…
General information only. Not legal or tax advice.
Notice details
- Notice code
- Letter 3846
- 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)
- 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
You will receive this letter from Appeals when you have filed a request for Collection Due Process (CDP) and/or Equivalent hearing (EH) request. This is the first step in the appeals process, informing you about a conference, acknowledging the assigned Appeals Officer, and affording you the opportunity to state why you disagree with the collection action taken by Compliance and request a collection alternative to resolve the tax liability. This letter informs you that one or more of the issues raised in your CDP/EH request were based on frivolous argument s or reflect s a desire to delay or impede tax administration . Appeals will disregard the frivolous, argument / or the issue considered t
Source: IRS Taxpayer Advocate Service. Reproduced for reference. General information — not legal or tax advice.
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-3846/
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.
Check this notice’s deadline (free tool)