IRS CP297 Notice: Final Notice of Intent to Levy (Business)
A CP297 is the IRS's final notice of intent to levy sent to a business — usually over unpaid payroll taxes — giving you exactly 30 days to request a Collection Due Process hearing before the IRS can levy bank accounts, receivables, and other business property.
Deadline calculator
The CP297 clock runs from the date printed on the notice — not the day you opened it.
Estimate only, based on the standard 30-day CP297 window. Your notice controls — always use the specific date printed on it.
What a CP297 actually means
The CP297 is the business-side twin of the CP90/LT11 final notices individuals receive. It means the balance — most often employment taxes from Forms 941 — has moved through the reminder sequence without resolution, and the IRS is one step from taking money: business bank accounts, merchant deposits, and accounts receivable (a levy served on your customers) are all fair game after the window closes.
Payroll tax debt is the debt the IRS chases hardest, because most of it is money withheld from employees' paychecks. If the business can't pay, the IRS can pursue the Trust Fund Recovery Penalty — personally assessing the trust-fund portion against owners, officers, or anyone who controlled the money. That makes the 30-day CDP window on a CP297 doubly important: it's your chance to set a resolution before both the business and its people are exposed.
How to recognize a real CP297
IRS collection sends it to a business after earlier notices didn't produce full payment. It's the notice required by Internal Revenue Code section 6330 that gives the right to a Collection Due Process hearing before a levy.
- The headline reads "Intent to seize your assets and notice of your right to a hearing," followed by "Amount due immediately" in large type.
- The upper-right box shows a Taxpayer ID number in employer (EIN) format. A billing summary breaks out the amount owed, added late-payment penalty, and added interest.
- The opening paragraph gives a specific date by which to request a CDP hearing. By law that deadline is 30 days after the end of the five-business-day period that follows the lien filing; the date printed on your letter is the one to use.
- The enclosures are listed at the end: Publication 594 (The IRS Collection Process), Publication 1660 (Collection Appeal Rights), and Form 12153 (Request for a Collection Due Process or Equivalent Hearing).
- The billing table lists each tax period with its form number. On the IRS sample, it's a Form 941 quarter.
What to do, step by step
- 1Mark the 30-day deadline from the notice date — the Collection Due Process window is strict.
- 2File Form 12153 (Request for a Collection Due Process Hearing) before the deadline; a timely request generally stops levy action while the case is heard.
- 3Get current on filings and federal tax deposits — the IRS won't grant a payment arrangement to a business that's still falling behind on this quarter's deposits.
- 4Prepare business financials (Form 433-B) and propose a realistic resolution: an in-business installment agreement, or an Offer in Compromise where the numbers support one.
- 5If payroll taxes are involved, get professional representation now — the Trust Fund Recovery Penalty interviews (Form 4180) that often follow are not something to walk into unprepared.
Illustrative example
Example: a CP297 for one missed payroll quarter
A small landscaping company owned by Ray (an illustrative business, not a real client) fell behind on payroll deposits for one Form 941 quarter and set the reminder notices aside during a slow winter. In February a CP297 arrived showing $8,930 due immediately and a hearing-request date 30 days out.
Ray's bookkeeper confirmed the 941 balance on the account transcript and made sure the current quarter's deposits were being made. Then they filed Form 12153 by the printed date, asking for a CDP hearing and proposing an installment agreement. The notice says that if you don't file Form 12153 by that date, you lose the ability to challenge Appeals' decision in U.S. Tax Court.
They also read the penalty section closely. If a Notice of Intent to Levy isn't paid within 10 days, the late-payment penalty rises from 1/2% to 1% per month. So they paid down part of the balance right away while the hearing request was pending.
Names and numbers are made up to show how this notice typically plays out.
Mistakes that make a CP297 worse
- Mailing Form 12153 to a general IRS address. The notice says to send it to the address at the top of page 1 and to state your reason for a hearing in section 8 of the form.
- Missing the printed date and planning to appeal later. A late request can still get an equivalent hearing, but the notice warns that you lose the right to take Appeals' decision to Tax Court.
- Assuming the levy can only reach the business bank account. The notice lists wages and other income, bank accounts, business assets, personal assets including cars and homes, and Social Security benefits as property that can be taken.
- Ignoring the lien warning. The notice says the IRS can file a Notice of Federal Tax Lien at any time if you don't pay or make arrangements, and the lien reaches property acquired later too.
What happens if you ignore a CP297
After the date printed on the notice, the IRS says it may seize (levy) the business's property or rights to property. It can also file a Notice of Federal Tax Lien. Separately, the late-payment penalty on the balance rises to 1% per month if the amount isn't paid within 10 days of the Notice of Intent to Levy.
Often comes before a CP297
Common questions
What's the difference between a CP297 and a CP90?+
Same letter, different taxpayer: the CP90 goes to individuals, the CP297 goes to businesses. Both are final notices of intent to levy carrying the 30-day Collection Due Process appeal right — the last required warning before the IRS can seize funds.
Can the IRS levy my business bank account after a CP297?+
Once the 30-day window passes without a CDP request or a resolution, yes — bank accounts, merchant processors, and even your customers (through an accounts-receivable levy) can be served without further warning.
Can the IRS come after me personally for my company's payroll taxes?+
For the trust-fund portion — the income tax and FICA withheld from employees' checks — yes. The Trust Fund Recovery Penalty lets the IRS assess that amount personally against anyone who was required to collect and pay it and willfully didn't, including owners, officers, and sometimes bookkeepers. Corporate or LLC structure does not block it.
What is a CP297A?+
A CP297A says the IRS has already issued a levy — typically on a state tax refund or federal contractor payments — and explains your hearing rights after the fact. It's a step past the CP297, and the account needs immediate attention.
Checked against IRS primary sources — see how we source these guides. You can verify any notice directly at IRS.gov. The dates and instructions printed on your specific notice always control. Official IRS explanation: Understanding your CP297 notice (IRS.gov).
- IRS: Understanding your CP297 notice
- IRS sample notice CP297 (PDF)
- IRS: Letters and notices offering an appeal opportunity
Go deeper
Received a CP297? Get it handled.
Talk to a tax specialist about your notice — free, no pressure, no judgment.