IRS NOTICE REFERENCE
Letter 4390
This letter is issued to you when Appeals makes a determination about the collection actions raised in your Collection Due Process (CDP) hearing and your request for relief from joint and several liability (Innocent Spou…
General information only. Not legal or tax advice.
Notice details
- Notice code
- Letter 4390
- 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; §6015 (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
This letter is issued to you when Appeals makes a determination about the collection actions raised in your Collection Due Process (CDP) hearing and your request for relief from joint and several liability (Innocent Spouse relief).
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. If you disagree with the determination of Appeals regarding the Collection Action ( Lien or Levy ) you can file a petition with the United States Tax Court within 3 0 days from the date of the Letter 4390 and is stated in the letter. The time you have to file a petition with the Tax Court is set by law and can’t be extended or suspended, even for reasonable cause. The IRS or TAS can’t change the allowable time for filing a petition with the Tax Court. The 30-day period is suspended during any time that you’re prohibited from petitioning the Tax Court due to the filing of a bankruptcy petition, plus an additiona
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-4390/
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)