IRS Notice · CP297 · Business Final Notice · Panic

CP297: the Final Notice on a business account

A CP297 is the Final Notice of Intent to Levy on a business account. Here's what the IRS can reach, what the 30 days is for, and where personal exposure starts.

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A CP297 is the last letter before the IRS can levy a business account. Here's what it can reach, what the 30 days is actually for, and the question underneath it that most owners haven't asked yet.

A levy on a business is not just a withdrawal. A bank levy freezes the account the payroll runs from. A receivables levy tells your customers, in writing, that the IRS is collecting from you. That second one does damage out of all proportion to the money involved, and it is the reason this letter deserves a different response from the ones before it. You have 30 days from the date printed on this notice to request a Collection Due Process hearing on Form 12153. It is the only window in this sequence you can permanently lose, and it is enough time to do something with.

(800) 236-3741, or (502) 658-6328 locally — answered 24 hours a day, seven days a week. After hours you reach our AI receptionist, not voicemail — it answers the common questions, takes your details, and books you the first available thirty minutes. During office hours you reach the office directly, in Georgetown.

The first call is free. Thirty minutes. No obligation, no conditions, no strings. Book a time →, or call the numbers above.

Thirty minutes tells you how much of the balance is trust fund tax, what the personal exposure behind it looks like, and whether the account your payroll runs from is exposed.

Every case here is reviewed and worked by Katherine personally. Not a processing department, and not a case manager relaying messages from someone you never meet.

Key takeaways

•A CP297 is the Final Notice — Notice of Intent to Levy and Notice of Your Right to a Hearing, issued on a business account. Its printed heading reads "Intent to seize your assets and notice of your right to a hearing."
•You have 30 days from the date on the notice to request a Collection Due Process hearing, on Form 12153.
•It is the business counterpart of a CP90. Same rights, same deadline, same form.
•A bank levy freezes funds and the bank holds them 21 days before remitting — a genuine window.
•If any part of the balance is trust fund tax, there is a second and personal exposure that this notice does not mention. That is the question worth asking this week.

What a CP297 is

A CP297 is the Final Notice of Intent to Levy sent on a business account. The IRS's summary is short: "We are notifying you of our intent to levy certain assets for unpaid taxes." The notice itself is titled Intent to seize your assets and notice of your right to a hearing, and it says you "can appeal the proposed seizure (levy) of your assets by requesting a Collection Due Process hearing (Internal Revenue Code Section 6330)" by the date it prints.

It exists because section 6330 of the tax code requires the IRS to notify you in writing of your right to a hearing at least 30 days before levying. The Taxpayer Advocate Service lists CP297 among the notices carrying those rights, alongside CP90, LT11 and Letter 1058.

The relationship between the codes is administrative rather than substantive: CP90 is the individual account version, CP297 the business one, LT11 comes from the automated system and a Letter 1058 from an assigned revenue officer. The rights are identical under all four.

Your clock

30 days from the date printed on the notice to request a Collection Due Process hearing, on Form 12153.

From the date on the notice, not from the day it arrived — the regulation at 26 CFR 301.6330-1 runs the period from the day after the date of the notice and states that actual receipt is not a prerequisite. Publication 1660: "During the 30-day period from the date of the notice, you may request a hearing with Appeals."

While a timely request is pending, levy action is not permitted for that tax and period, with narrow statutory exceptions. It also suspends the ten-year period the IRS has to collect, until Appeals' determination becomes final or you withdraw the request in writing — a real cost, and one that matters more on a business account where several periods may be running separate clocks.

If the 30 days has gone, an equivalent hearing is available for a year from the date of the levy notice. Levy action is not prohibited during it — Appeals may ask for a hold, but nothing obliges it — the collection period is not suspended, and it cannot be taken to Tax Court. Treat it as a conversation without protection.

Sources: IRS, "Understanding your CP297 notice" and Notice CP297; IRS Publication 1660; 26 CFR 301.6330-1. Reviewed 27 August 2026.

What the IRS can reach on a business

What	How it behaves
Bank accounts	The bank freezes the funds and holds them 21 days before sending them to the IRS. That hold is a real window, and it is sometimes long enough to get a levy released before the money moves
Accounts receivable	A levy served on your customers. The commercial damage usually exceeds the amount collected
Wages and commissions	Continuous once attached, until released or the balance is paid
Business assets	Equipment, vehicles, and in some circumstances property
State tax refund	Can be taken without a further letter — a separate carve-out in section 6330(f)

The receivables levy is the one to plan around. Everything else on this list is a financial event. That one is a communication to your customers, and it changes a commercial relationship in a way that outlasts the tax problem.

The question this notice does not ask

If any part of the balance is payroll tax, the business is not the only party exposed.

The portion of employment tax withheld from employees' wages — the trust fund portion — can be assessed personally against individuals the IRS determines were responsible for paying it over and willfully failed to do so. That is a separate process, with its own letter and its own protest window, and it does not go away if the business does. Closing the entity does not close it.

Nothing on a CP297 announces this and nothing about receiving one means it is coming. But it is the fork in the road that determines what this file is actually about, and the answer is on the account rather than in the letter: which periods, which forms, and how much of each balance is trust fund. How personal liability for payroll tax actually works →

The 30-Day Levy Response Checklist

What to pull, what to confirm before you call, and what has to happen before day 30 — the order we work in here. It asks for a first name and an email address. These sheets carry dated figures, and the list is how a correction reaches you when one of them changes.

If payroll runs from the account named on this notice, that is worth a call today rather than a decision alone. (800) 236-3741, or Book thirty minutes →.

The situations that change this answer

Asking for a payment plan or an offer bars the levy while it is being processed. Section 6331(k): no levy may be made while a request for an installment agreement or an offer in compromise is pending, for 30 days after a rejection, during an appeal of that rejection, or while an agreement is in effect. For a business facing a receivables levy this is the most valuable thing on the page, because the commercial damage is done the moment your customers receive the notice — and once a request is accepted for processing, the statutory bar is what keeps a further levy from reaching them. It is not instant and it is not absolute: it runs from acceptance for processing, it covers only the periods the request covers, and section 6331(k)(3) borrows the exceptions in 6331(i)(3), so it gives way to a jeopardy finding and does not stop a federal refund being taken as an offset.

The protection starts, for an offer, "on the date the Secretary accepts such offer for processing" — not the day you send it — and it bars levy rather than lien filing. It also does not undo a levy already served, which is the release question below.

🔴 If your letter says CP297A or CP297C, the levy has already happened. The Taxpayer Advocate Service lists both alongside CP297, which makes them easy to mistake for it — but their printed heading reads Notice of seizure and notice of your right to a hearing. A CP297A follows a disqualified employment tax levy; a CP297C follows a federal contractor levy. In both, the hearing comes after the levy rather than before it.

What still applies from this page: the 30 days, Form 12153, the release grounds, and the trust fund section. What does not: everything about what happens before a levy — the waiting period, "not on this notice alone," and moving the payroll account ahead of time. For that architecture, CP90C is the same situation on the individual side.

Employment tax has a shorter path, but it is narrower than its name. Section 6330(f)(3) excepts a disqualified employment tax levy from the pre-levy hearing requirement — one of four carve-outs, with a jeopardy finding, a state refund levy, and a federal contractor levy. In each of those the hearing follows the levy instead of preceding it.

But section 6330(h)(1) defines the employment-tax one narrowly: it reaches a levy for employment taxes only where the taxpayer "(or any predecessor thereof) requested a hearing under this section with respect to unpaid employment taxes arising in the most recent 2-year period" before the period being levied. A prior Collection Due Process hearing request on payroll tax, within two years — not simply having payroll tax in the balance. For most businesses that has never happened and the protection is intact.

If a levy has already been served, the question is release. Section 6343 requires the IRS to release a levy where the balance is paid, where the collection period has expired, where release will help you pay, where you enter an installment agreement whose terms do not allow the levy to continue, where the levy creates an economic hardship, or where the property is worth more than the debt and partial release would not hinder collection. Section 6343(d) separately allows property already taken to be returned where the levy was premature or did not follow administrative procedure — a narrower and later remedy, and not the same thing as release.

Not everything is reachable in the same way — but check which of these is actually yours. Section 6334 exempts books and tools of a trade up to an annually adjusted amount. It also gives property used in a trade or business a procedural protection: no levy without a written determination that your other assets are insufficient, or a jeopardy finding.

That second protection is written for an individual taxpayer. Section 6334(a)(13)(B)(ii) covers property used in the trade or business "of an individual taxpayer" — so a sole proprietor has it and an incorporated business or an LLC does not. If the equipment belongs to the entity rather than to you, it carries no procedural protection beyond the ordinary rules.

A principal residence is different again, and it is yours personally: exempt from levy unless a judge or magistrate of a United States district court approves the levy in writing.

And there is a second deadline after the hearing. If Appeals decides against you, section 6330(d)(1) gives 30 days from the determination to petition the United States Tax Court. Only one CDP hearing is available per taxable period under section 6330(b)(2) — which matters on a business account, where several quarters may each be at a different stage.

If you want the trust fund share of the balance worked out before you decide anything: (800) 236-3741, or Book thirty minutes →. That number decides how much of this is the company's problem and how much is yours.

What to do in the next 30 days

Move the payroll account before you need to, not after.

If the account the payroll runs from is the account the IRS knows about, a levy stops your employees being paid. That is a practical step, not a hiding one — and doing it while planning to resolve the balance is different from doing it to evade collection. This is first on the list because it is the only item that has to happen before a levy lands rather than after. Everything below still works next week. This does not.

Count 30 days from the date on the notice.

Write the date somewhere the whole management of the business can see it.

Establish how much of the balance is trust fund tax.

Before anything else. It changes who is exposed, what the options are, and how urgent this is.

Get current on filing and on current deposits.

This is the single largest determinant of how the case goes. A business that is accruing new liability while negotiating about old liability has already answered the IRS's main question, and not favorably.

Pull the transcripts for every period involved.

Free, and you can request them yourself. Business accounts commonly carry balances across several quarters with different assessment dates and different clocks. Reading them is the harder part, and on a business account it answers the question that really matters here: how much of the balance is trust fund tax, period by period.

Decide about the hearing, and file Form 12153 inside the 30 days if you want it.

A timely request normally stops levy action for that tax and period while it is pending. It also pauses the ten-year collection clock. Both are worth weighing rather than assuming.

If a revenue officer is assigned, the timetable is theirs as well as the statute's.

What changes when a person has your file →

What happens if you do nothing

After the 30 days the IRS can levy the business account and serve your customers.

Two consequences, and the second is the one businesses underestimate. A bank levy freezes the account payroll runs from. A receivables levy is a letter to your customers telling them, in writing, that the IRS is collecting from you — and that changes a commercial relationship in a way that outlasts the tax problem.

And behind both, the personal one. If any of the balance is trust fund tax, that liability is assessed against individuals, it survives the entity, and it follows people to their own returns. Closing the business does not close it. That question runs on its own clock and it does not stop when this letter's 30 days do.

Katherine M. Johnson, CPA, CTRS

Katherine M. Johnson is a licensed CPA with over 30 years of experience and a Certified Tax Resolution Specialist (CTRS). She personally handles every case — representing individuals and businesses before the IRS and state revenue departments nationwide.

Read full bio

The Kentucky note

A Kentucky business with a federal balance almost always has a state one, and the state's collection process is shorter and broader.

Kentucky's Department of Revenue can levy administratively, without a court judgment, once an assessment is final and the tax has been unpaid for 30 days after demand. Its statutory floor before levying is a written notice of intention, given in person or by certified mail to the last known address, no less than ten days before the levy date under KRS 131.510(1). The federal floor on the same step is 30 days before the levy, under section 6331(d) — which is a different 30 days from the one on your notice, and it is the IRS's waiting period rather than your window to file anything.

Two Kentucky powers have no federal equivalent and both bite hardest on businesses. KRS 131.1817 reaches professional and occupational licenses issued by state licensing agencies, attorney licenses through the Kentucky Supreme Court, and vehicle registration — and its definition of a delinquent taxpayer includes failing to file a required return within 90 days of the due date after department contact, regardless of any balance owed. And there is no state analogue to the hearing right your CP297 carries: Kentucky's review is a 60-day protest at the assessment stage, in writing, and once it closes there is no second door.

A federal payment plan does not touch any of it. How a Kentucky balance and an IRS balance interact →

Sources: KRS 131.500(1); KRS 131.510(1); KRS 131.1817 (as amended 27 June 2025); KRS 131.110(1)(a). Kentucky Legislative Research Commission. Reviewed 5 September 2026.

What we see

When a business brings us a CP297, the first place we look is the current deposits rather than the historical balance — an entity still accruing new liability while it negotiates about the old liability has answered the IRS's main question before anybody opens a file. The second thing we do is split the balance into a trust fund and everything else, period by period, because owners routinely read one number where the account holds two very different exposures. What surprises people most is that the trust fund portion is not the company's to carry alone: it is assessed against individuals, and dissolving the entity does nothing to it. That is usually the point where the question stops being what the business should do and becomes what the people behind it should do.

Katherine — You're welcome to replace this with what a CP297 actually looks like in practice.

Katherine is a CPA, which places her in the category of representative the IRS recognizes as having unlimited rights to act for a taxpayer before it. On a business account with several periods live, the practical value is narrow and real: a Power of Attorney gets the full account read directly, period by period, rather than reconstructed from whichever letters happen to have arrived.

When this is the wrong page

If the business has already closed and there are no assets, a CP297 is largely a letter about an empty room. The IRS can levy what exists, and what does not exist cannot be levied — defending an empty entity against a collection action is not where the effort belongs. The live question in that situation is the personal one: whether trust fund liability is going to be assessed against individuals, which survives the entity and follows people to their own returns.

Which is why these are the ones worth a call, closed entity or not:

Any part of the balance is trust fund tax. That exposure is personal and it does not die with the company.
The business is still trading and payroll runs from the account named on this notice. A levy there stops your employees being paid.
Your receivables are the exposure. The damage is done the moment your customers receive the notice.
Several quarters are live at different stages, so one date on one letter does not describe the account.

Working out which of those is you takes one read of the account. (800) 236-3741, or Book a time →.

Where this sits in the sequence

Notice	What it is
CP504B	Before this. The business notice of intent to levy.
CP297▶ You are here	The Final Notice carrying your hearing right on a business account. 30 days from the date on the letter.
Form 4180	The interview that decides personal liability, if employment tax is involved.
Letter 1058	If a revenue officer sent yours — the same instrument, from a person.

Before: CP504B — the business notice of intent to levy → The individual version of this letter: LT11 — the Final Notice in full → If a revenue officer sent yours: Letter 1058 → All notices: The IRS notice index → If a levy reaches the bank: Bank levy release →

Frequently asked

Can the IRS levy my business bank account immediately?

Not on this notice alone — the 30 days from the date on it has to run first, and while a timely hearing request is pending levy action is not permitted for that tax and period. If a levy does reach the bank, the bank holds the funds for 21 days before remitting them.

Can the IRS contact my customers?

A receivables levy is served on the people who owe your business money, and it tells them to pay the IRS instead. That is a normal collection tool at this stage rather than an unusual one.

Is a CP297 the same as a CP90?

Same instrument, different account type — CP90 on an individual account, CP297 on a business one. Same 30 days, same Form 12153, same rights.

If I close the business, does this go away?

The levy exposure follows the assets, so an entity with nothing has little for the IRS to take. Trust fund liability is different: it is assessed against individuals and it survives the entity. Closing a business is not a way out of that part.

Does requesting a hearing stop the clock on everything?

While it is pending, levy action is not permitted for that tax and period, narrow exceptions aside, and the ten-year collection period is suspended until Appeals' determination becomes final or the request is withdrawn in writing. It does not stop interest and penalties accruing.

If you'd rather not work it out alone

We handle IRS collection matters for small businesses from our office in Georgetown, Kentucky. If a CP297 has arrived, we can pull every period on the account, tell you exactly how much of the balance is trust fund tax, and say what the personal exposure looks like.

Which of two situations you are in decides how urgent this is. If the business is still trading and payroll tax is in the balance, the timing matters this week: the receivables exposure is real and the request that bars a levy has to be in. If the entity is closed and empty, the levy side is largely over and what remains is the personal trust fund question — which does not go away, and is better handled with room than in a hurry.

The first call is free. Thirty minutes. No obligation, no conditions, no strings. You will come away knowing how much of the balance is trust fund tax, what the personal exposure behind it looks like, and whether the account your payroll runs from is exposed. You do not need paperwork organized; the notice and a rough sense of which quarters are involved is enough to start.

Call (800) 236-3741, or (502) 658-6328 locally — or Book a time →. The line is answered 24 hours a day, seven days a week, so if it is late and you have just opened the envelope you can start tonight. After hours you reach our AI receptionist rather than voicemail — it answers the common questions, takes your details, and books the first available thirty minutes. Katherine works the account herself.

Call (800) 236-3741 Book a time

This article is general information, not tax advice for your situation. Every account is different, the options described here are not available to everyone, and no outcome is guaranteed.

Next Level Tax Resolution is a private CPA firm in Georgetown, Kentucky. We are not affiliated with, endorsed by, or acting on behalf of the Internal Revenue Service, the Kentucky Department of Revenue, or any government agency.

The NLTR Office ·

Reviewed by Katherine M. Johnson, CPA, CTRS