IRS vs FTB vs CDTFA – Who Comes After You First in California?
When you owe taxes to more than one agency, it’s hard to know who to deal with first.
Should you respond to the IRS, the Franchise Tax Board (FTB), or the California Department of Tax and Fee Administration (CDTFA)?
In California, you might get hit by all three — and they don’t wait for each other.
But each agency follows a different timeline and method for enforcement. This guide will help you understand:
- Which agency usually acts first
- Who is most aggressive
- How notices and collections escalate
- What to prioritize when facing multi-agency enforcement
- How to protect your income and accounts
Overview of Each Agency
| Agency | What It Enforces | Common Triggers |
|---|---|---|
| IRS | Federal income, payroll, and business taxes | CP14, CP504, LT11, Letter 1058 |
| FTB | CA personal income tax, LLC/LP taxes | FTB 4905, FTB 4930, suspended entity |
| CDTFA | Sales & use tax, excise tax, cannabis tax | Notice of Determination, past-due sales tax return |
Who Usually Acts First?
1. CDTFA – Most Aggressive
If you’ve failed to file or pay California sales tax, the CDTFA can:
- Issue a
Notice of Determination
- File a lien
- Levy your bank account — often within
30–45 days of notice
They don’t need to wait on federal data — they calculate estimated tax bills quickly and issue assessments even if you’re out of compliance.
2. FTB – Fastest to Levy
The FTB moves faster than the IRS in most cases. If you ignore FTB notices, they may:
- File a
state tax lien
- Issue a
bank levy with
10-day hold
- Garnish wages with minimal warning
FTB collections often begin just 2–4 weeks after the last notice.
3. IRS – Most Bureaucratic, but Still Dangerous
The IRS gives more warnings and a longer notice cycle. However, once it issues a Final Notice of Intent to Levy, collections can start in 30 days.
IRS enforcement includes:
- Bank levies
- Wage garnishment
- Seizure of federal refunds
- Passport restrictions (for large debts)
Can More Than One Agency Levy You at the Same Time?
Yes. It’s common for California taxpayers to experience:
- IRS wage garnishment
- FTB bank levy
- CDTFA sales tax lien
...all in the same month.
Because these agencies don’t coordinate, you must address each one separately.
What to Do When More Than One Agency Is Coming After You
Step 1: Identify the Agency with the Highest Risk
- Who has already levied your bank account?
- Who sent a
final notice?
- Which debt could impact your license or business?
Start with whoever is actively enforcing collections — usually CDTFA or FTB.
Step 2: Request Holds from All Agencies
You can usually get a temporary hold on enforcement while:
- Submitting financial disclosure
- Negotiating a payment plan
- Filing an Offer in Compromise
Step 3: Prioritize Based on Revenue Size and Penalties
- IRS often takes longer to process OICs but has more flexible programs
- CDTFA can assign a field auditor and assess large penalties fast
- FTB can freeze accounts and intercept refunds more easily
Pro Tip: Handle All Three Together
You can prepare one unified financial package (income, expenses, assets) and use it to:
- Apply for an IRS Offer in Compromise
- Submit FTB hardship request or OIC
- Negotiate CDTFA resolution or appeal
Why Work With a CPA for Multi-Agency Defense
At Boulanger CPA, we:
- Coordinate IRS, FTB, and CDTFA resolutions
- Stop levies and garnishments from all agencies
- Prepare offers and appeals tailored to each one
- Protect your assets and income with smart negotiation
📞 Call 657-218-5700 or Schedule a Consultation
Frequently Asked Questions
Which agency usually collects first in California?
In most cases, the CDTFA acts first, followed by the FTB, then the IRS. The CDTFA is fastest with bank levies and assessments.
Can I be levied by more than one agency at once?
Yes. It’s common for the IRS, FTB, and CDTFA to issue simultaneous levies or garnishments if you owe each of them money.
How do I stop all tax agencies from collecting at once?
You’ll need to contact each agency separately and request a hold while you submit a financial disclosure and negotiate resolution terms.
Can one resolution apply to all agencies?
No. You must file separate Offers in Compromise or payment plans with each agency, even if the financial data overlaps.
What happens if I ignore collection notices?
You may be hit with multiple levies, garnishments, liens, and other enforcement actions that can spiral out of control.
📣 About the Author
Marc Boulanger, CPA is the founder of Boulanger CPA and Consulting PC, a boutique tax resolution firm based in Orange County, California and trusted by high-income individuals and business owners across Southern California.
He is the author of Defend What’s Yours: A California Taxpayer’s Guide to Beating the IRS and FTB at Their Own Game, available now on Amazon. The book offers a step-by-step plan for resolving IRS and FTB tax debt without losing your business, your home, or your peace of mind.
With over a decade of experience resolving high-stakes IRS and State tax matters, Marc brings strategic insight to complex cases involving wage garnishments, bank levies, unfiled returns, and six-figure tax debts. He is known for helping clients reduce or eliminate tax liabilities through expertly negotiated settlements and compliance plans.
Marc is a Certified Public Accountant licensed in California and Oklahoma and holds the designation of Certified Tax Representation Consultant. He is a member of the American Society of Tax Problem Solvers (ASTPS) — the national organization founded by the educators and practitioners who have trained thousands of CPAs, EAs, and tax attorneys in IRS representation strategy.
Every case is handled with discretion, proven methodology, and direct CPA-led representation — not call center scripts.
📍 Learn more at www.orangecounty.cpa or call (657) 218-5700.
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