Appendix G: How Long Things Take
Compare typical IRS process timelines with actual filing deadlines. Check CDP, equivalent-hearing, CAP and Tax Court timing rules and their limits.
Typical timeframes under current IRS conditions, which the National Taxpayer Advocate has described as strained. Treat these as planning ranges, not promises. Where a legal deadline exists, it is marked; everything else is practice.
Scroll horizontally if needed to see all columns.
| Process | Typical time | Legal deadline, if any |
|---|---|---|
| Reaching someone by phone at the IRS | 30 minutes to 2 hours on hold; longer in tax season | None |
| Setting up an IRS Online Account | 15 to 30 minutes | None |
| Streamlined installment agreement, online | Approved on screen | None |
| Installment agreement by phone or Form 9465 | Same call, or 4 to 8 weeks by mail | None |
| Non-streamlined agreement with revenue officer | 2 to 8 weeks after complete financials | None |
| Bank levy: funds held before remittance | 21 days | 21 days by statute (section 6332(c)) |
| Levy release once approved | Same day by fax to 1 week | 30 days for the IRS to issue once release is required |
| Currently Not Collectible determination | Same call to 4 weeks | None |
| First Time Abate by phone | Same call | None |
| Reasonable cause penalty request by mail | 2 to 6 months; longer if appealed | None to request; 30 days to appeal a denial |
| Audit reconsideration or replaced substitute return | 2 to 6 months; longer in backlogs | None |
| Offer in Compromise, submission to decision | 6 to 12 months; some longer | Deemed accepted if no decision in 24 months |
| Offer rejection appeal | 30 days to file; 3 to 6 months to decide | 30 days to appeal |
| Collection Due Process hearing request | Follow the printed deadline; lien and levy clocks differ | Levy: printed 30-day CDP period; lien: 30-day period following five business days after lien filing |
| CDP hearing, request to conference | 3 to 6 months | None |
| CDP determination to Tax Court petition | 30 days from mailing of the determination; file with the Court | Equitable tolling may apply exceptionally under Boechler; not a routine extension or deficiency-case rule |
| Equivalent hearing request | Levy: within one year of levy CDP notice; lien: one year plus five business days from lien filing | No statutory levy prohibition, collection-statute suspension or ordinary CDP Tax Court review |
| Collection Appeals Program decision | Timing varies; do not wait for a predicted processing time | Revenue-officer lien/levy: notify within 2 business days of manager conference; Form 9423 postmark within 3; seizure, manager nonresponse and agreement decisions have separate rules |
| Innocent spouse determination | 6 to 18 months | 2 years from first collection action for traditional and separation relief |
| Trust Fund Recovery Penalty protest | 60 days to file; 3 to 9 months to decide | 60 days by statute |
| Lien release after full payment | Within 30 days | 30 days by statute |
| Lien withdrawal, discharge, or subordination | 30 to 60 days | None; the IRS asks for 45 days on discharge and subordination |
| Identity theft case resolution | Well over a year at recent inventory levels | None |
| Taxpayer Advocate case acceptance | Days for hardship cases; weeks otherwise | None |
| Passport decertification after resolution | Several weeks | 30 days for the IRS to notify State after the condition is cured |
| Collection statute | 10 years from assessment plus suspensions | Section 6502 |
Two reminders. The deadlines in the right column are not extendable because you were on hold, did not understand the letter, or were waiting for a representative to call back. And the practice ranges in the middle column lengthened materially during 2025 and 2026; if your matter is taking longer than the range, that is a reason to follow up in writing and to consider the Taxpayer Advocate, not a sign that something has gone wrong with your case.
Hearing timing and procedures: IRS Publication 1660, pages 1–2 and Form 12153 and instructions, source-checked October 30, 2026. See Chapter 16 for the lien, levy and equivalent-hearing distinctions.
Verify the appeal clock before filing
IRS Publication 1660, Collection Appeal Rights, pages 3–4, distinguishes CAP's two-business-day notification from its three-business-day postmark step. A manager who does not respond triggers a separate four-business-day procedure; a seizure has a 10-business-day manager-appeal window. Installment-agreement decisions generally have separate 30-day appeal periods. Do not apply one deadline to every collection action.
A deficiency petition generally has 90 days from notice mailing, or 150 days if addressed outside the United States; a CDP determination generally has 30 days from mailing. File the petition with the Court, not IRS Appeals. DAWSON receipt generally must occur by 11:59 p.m. Eastern Time; paper-mailing and designated-delivery rules differ. Tax Court guidance for starting a case explains filing and privacy. Boechler v. Commissioner permits equitable tolling of the CDP petition deadline in appropriate cases, not an automatic extension or a universal rule for deficiency petitions.