IRS Letter 3193: Notice of Determination (CDP)

Letter 3193 is the Notice of Determination issued by the IRS Office of Appeals at the end of a Collection Due Process (CDP) hearing. It is the formal document that closes the administrative CDP process and starts a 30-day clock to petition the United States Tax Court. If no petition is filed within 30 days, the determination becomes final and the IRS can resume collection on the terms stated in the notice.

The 30-Day Tax Court Petition Deadline

Under IRC Section 6330(d)(1), you have 30 days from the date of Letter 3193 to petition Tax Court for review. The deadline is jurisdictional. The Tax Court cannot accept a late petition. Count 30 days from the date on the letter. A petition mailed on time can qualify under the timely-mailing rule, but the safest route is electronic filing through the Tax Court's DAWSON system well before the deadline.

What Tax Court Can Review

The Tax Court reviews the determination for abuse of discretion. The court looks at whether Appeals considered the issues properly, whether it balanced the IRS's need for efficient collection against the taxpayer's concerns about intrusiveness, and whether the collection alternative decision was supported by the record. If the taxpayer raised the underlying tax liability and had not had a prior opportunity to challenge it, the court can review the tax liability itself on a de novo basis.

Collection During the 30-Day Window and After

Collection action is suspended during the 30 days following Letter 3193 and, if a timely Tax Court petition is filed, throughout the Tax Court proceeding. If no petition is filed, collection resumes on day 31. If the Tax Court case is lost or dismissed, collection resumes after the case closes.

Equivalent Hearing Decisions

Letter 3193 is for timely-filed CDP hearings only. Equivalent Hearing decisions issue on Letter 3210 and do not carry Tax Court petition rights. Confirm which letter you received before calculating any Tax Court deadline.

If you received Letter 3193, call us at (813) 229-7100 today. The 30-day petition clock does not wait.