IRS NOTICE REFERENCE
Letter 4380
You will receive this letter from the Independent Office of Appeals (Appeals) when you have filed a request for Collection Due Process (CDP) and/or Equivalent Hearing based on a frivolous position or with the intent to d…
General information only. Not legal or tax advice.
Notice details
- Notice code
- Letter 4380
- 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
You will receive this letter from the Independent Office of Appeals (Appeals) when you have filed a request for Collection Due Process (CDP) and/or Equivalent Hearing based on a frivolous position or with the intent to delay or impede federal tax administration. Appeals will provide you with a 30-day deadline to either perfect the request or withdraw the request to avoid a possible penalty. If you do not amend or withdraw the CDP and/or Equivalent Hearing, Appeals will disregard your request and return your case to Collections.
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-4380/
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)