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Published:   |   Last Updated: January 6, 2024

Letter 5100

Collection Appeal Program (CAP) Decision Letter

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Station Overview

You requested a CAP appeal of a collection activity or warning of collection activity or property subject to collection action. This letter advises you that the review was conducted and the IRS Independent Office of Appeals (Appeals) reached a determination on the IRS decision that either the collection activity or warning of collection activity or property subject to collection action is either sustained or not.

This notice or letter may include additional topics that have not yet been covered here. Please check back frequently for updates.

What does this letter mean to me?

The letters advises you of Appeals’ determination on your case and the decision is final.  The case is returned to Compliance to carry out the determination.

How did I get here?

You have a balance owed on our tax account or you have property subject to a collection action.  You appealed one of the following actions:

  1. Levy or seizure action that has been or will be taken;
  2. NFTL that will be or has been filed;
  3. A filed special condition NFTL attaching taxpayer property held in the name of a third party (i.e. a nominee, alter ego, transferee, etc. NFTL);
  4. Denials of requests to issue lien certificates, such as subordination, discharge or non-attachment as well as denials of requests to withdraw an NFTL;
  5. Rejected, proposed for modification, modified, proposed for termination or terminated installment agreement;
  6. Disallowance of taxpayer’s request to return levied property under IRC § 6343(d); or
  7. Disallowance of third-party property owner’s claim for return of wrongfully levied property under IRC § 6343(b)

What are my next steps?

Your case is returned to Collection or the operating division that originated the action.

Where can I get additional help?

Understanding your notice or letter

Get Help topics

Browse common tax issues and situations at Get Help on the TAS website.

If you still need help

The Taxpayer Advocate Service is an independent organization within the IRS that helps taxpayers and protects taxpayers’ rights. We can offer you help if your tax problem is causing a financial difficulty, you’ve tried and been unable to resolve your issue with the IRS, or you believe an IRS system, process, or procedure just isn’t working as it should. If you qualify for our assistance, which is always free, we will do everything possible to help you.

Visit www.taxpayeradvocate.irs.gov or call 1-877-777-4778.

Low Income Taxpayer Clinics (LITCs) are independent from the IRS and TAS. LITCs represent individuals whose income is below a certain level and who need to resolve tax problems with the IRS. LITCs can represent taxpayers in audits, appeals, and tax collection disputes before the IRS and in court. In addition, LITCs can provide information about taxpayer rights and responsibilities in different languages for individuals who speak English as a second language. Services are offered for free or a small fee. For more information or to find an LITC near you, see the LITC page on the TAS website or Publication 4134, Low Income Taxpayer Clinic List.


Did you know there is a Taxpayer Bill of Rights?

The taxpayer Bill of Rights is grouped into 10 easy to understand categories outlining the taxpayer rights and protections embedded in the tax code.

It is also what guides the advocacy work we do for taxpayers.

Read more about your rights

Where am I in the tax system?

Letter 5100

Collection Appeal Program (CAP) Decision Letter