IRS NOTICE REFERENCE
Letter 4440
This letter is issued to the taxpayer when the IRS Independent Office of Appeals (Appeals) makes a determination on the taxpayers Collection Due Process (CDP) Equivalent Hearing request and interest abatement request.
General information only. Not legal or tax advice.
Notice details
- Notice code
- Letter 4440
- 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
- 180-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 the taxpayer when the IRS Independent Office of Appeals (Appeals) makes a determination on the taxpayers Collection Due Process (CDP) Equivalent Hearing request and interest abatement request.
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. Since your CDP request was not timely, you received an equivalent hearing and the IRS made a determination about your lien or levy. This decision cannot be reviewed further by the IRS or the Tax Court. However, as part of your CDP request, you raised an issue of interest abatement. The interest abatement issue can be appealed to the Tax Court. If you want to dispute the determination regarding your interest abatement request, you must file a petition with the Tax Court within 180 days from the date of the Letter 4440. The time you have to file a petition with the Tax Court is set by law and can’t be extended or
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-4440/
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)