CPA next steps after client receives bank account levy

Quick answer: For a bank account levy, the immediate priorities are: confirm the IRS actually sent the required pre-levy notice and CDP hearing rights, check whether a timely CDP hearing request or other release grounds apply, and remember a bank levy has a mandatory 21-day holding period before funds go to the IRS. This answer assumes 2025/2026 procedural rules under current IRC Chapters 64 and 76.

First, verify notice was proper

Before any levy (with a narrow jeopardy exception), the IRS must give written notice of the taxpayer's right to a CDP hearing. As the Code states, no levy may be made on any property or right to property of any person unless the Secretary has notified such person in writing of their right to a hearing under this section before such levy is made.¹ That notice must be given in person; left at the dwelling or usual place of business of such person; or sent by certified or registered mail, return receipt requested, to such person's last known address; not less than 30 days before the day of the first levy with respect to the amount of the unpaid tax for the taxable period.²

Separately, § 6331(d) requires its own 30-day notice of intent to levy before levying on "salary or wages or other property" — levy may be made under subsection (a) upon the salary or wages or other property of any person with respect to any unpaid tax only after the Secretary has notified such person in writing of his intention to make such levy,³ and that notice must be given in person, left at the dwelling or usual place of business of such person, or sent by certified or registered mail to such persons's last known address, no less than 30 days before the day of the levy.⁴ Confirm your client actually received (or the IRS mailed to the correct last-known address) both notices. If it didn't, that's a strong basis to challenge the levy.

Check CDP hearing rights and deadlines

Your client is entitled to only one hearing under this section with respect to the taxable period to which the unpaid tax specified in subsection (a)(3)(A) relates.⁵ If a CDP hearing was requested, it must be run by someone with no prior involvement in the case, though the hearing under this subsection shall be conducted by an officer or employee who has had no prior involvement with respect to the unpaid tax specified in subsection (a)(3)(A) before the first hearing under this section or section 6320. A taxpayer may waive the requirement of this paragraph.⁶ At the hearing, Appeals must obtain verification from the Secretary that the requirements of any applicable law or administrative procedure have been met.⁷

Immediate practical steps

1. Pull the levy notice and any prior CDP/intent-to-levy notices — check dates and delivery method against the rules above.
2. Ask the IRS for the levy source (Form 668-A for banks) and confirm the 21-day bank holding period — the documents don't cover this mechanic directly, so verify the exact rule with current IRS collection guidance.
3. Explore release grounds under IRC § 6343 (a document title is provided but no operative text is in your files — pull the full text before advising).
4. Consider an installment agreement, which is listed among alternatives the IRS must disclose: the notice required under paragraph (1) shall include a brief statement which sets forth in simple and nontechnical terms... the alternatives available to taxpayers which could prevent levy on the property (including installment agreements under section 6159).
5. If successive levies are a risk, note that under § 6331(c), whenever any property or right to property upon which levy has been made by virtue of subsection (a) is not sufficient to satisfy the claim of the United States for which levy is made, the Secretary may, thereafter, and as often as may be necessary, proceed to levy in like manner upon any other property liable to levy of the person against whom such claim exists, until the amount due from him, together with all expenses, is fully paid.⁸

For property exemptions from levy, general collection process background, and release procedures, review Pub. 594 (referenced but not included in these documents) and the full text of IRC §§ 6334 and 6343.

Risks and limits

The documents I have don't include the operative text of §§ 6334 (exempt property) or 6343 (release authority) — only their titles — so confirm those provisions directly before advising on exemption amounts or release standards.

Given the tight deadlines involved, this is a case where getting a CPA or attorney experienced in IRS collections involved immediately — including possibly requesting Appeals or a Taxpayer Advocate case — is worth doing right away rather than waiting.