Understanding Your CP94 Notice


A restitution-based assessment was made under Internal Revenue Code (IRC) Section 6201(a)(4), in accordance with the court’s restitution order. The amount due is based on the amount of restitution you were ordered to pay, as well as any other penalties and interest reflected on the billing summary.

What you need to do

  • Read your notice carefully.
  • Pay the amount by the due date to avoid additional interest and penalties.
  • Pay the amount due directly to the court and include a copy of this letter.

Frequently asked questions

What is the notice telling me?
A restitution-based assessment was recently made based on the court’s order.

Why is interest being charged to the restitution-based assessment? 
A restitution-based assessment is treated like any other assessment of tax under Title 26 of the IRC. Title 26 interest will accrue on the restitution-based assessment separately, even if the sentencing court waived Title 18 interest in whole or in part. For additional information, please see Chief Counsel Notice 2011-018 PDF.

My tax return for this year was audited. Why are you also assessing the court-ordered restitution? 
We're required to make an assessment for all court-ordered restitution payable to the IRS. Both the civil assessment and the restitution-based assessment modules will be linked to ensure you only pay the underlying tax liability once.

What do I have to do?
Pay the amount due shown on the notice to the court. Include a copy of this notice when making a payment to the court.

What happens if I don't pay?
Interest will continue to accrue and the amount you owe will increase.

Who should I contact?
If you have any questions about the notice, call us at the number printed at the top of the notice.

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