The LTR 321 is a status update from the IRS Office of Appeals. Your case is still pending. The Appeals Officer hasn't made a decision yet. This letter is administrative — it tells you the case is active and may provide information about next steps.
What It Typically Says
The LTR 321 may confirm your case is assigned and awaiting review, notify you that the Appeals Officer needs more time, request additional documentation or information, or provide scheduling information for an upcoming conference.
What to Do
If the letter requests action, respond by the stated deadline. If it's purely informational, file it with your case records. Continue preparing your documentation and arguments for when the Appeals Officer does schedule your conference.
If your CDP hearing request is pending and collection activity occurs despite the LTR 321 confirming your case is active, contact Appeals immediately with a copy of the letter.
Timeline Expectations
Appeals cases take 6 to 12 months on average. Some complex cases take longer. The LTR 321 is the IRS's way of keeping you informed during the wait. While frustrating, the processing time often works in your favor if collection is suspended during the pending appeal.
If your Appeals case seems stuck, call us at (813) 229-7100.