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Published:   |   Last Updated: June 5, 2023

Taxpayer Files Collection Appeal Program (CAP) Request

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Station Overview

These letters entitle you to request a Collection Appeal Program (CAP) appeal because you have property subject to collection action and received a collection action notice or warning of collection action. CAP is available for the following actions:

  • Before or after the IRS files a Notice of Federal Tax Lien;
  • Before or after the IRS levies or seizes your property;
  • Termination, or proposed termination, of an installment agreement;
  • Rejection of an installment agreement; and
  • Modification, or proposed modification, of an installment agreement.
  • After the denial of a request for property to be discharged from a lien. 
  • After the denial of the subordination of a lien. 
  • After the denial of the withdrawal of a NFTL. 
  • After the denial of the issuance of a certificate of non-attachment. 
  • After the disallowance of a taxpayer’s request for return of levied property under IRC 6343(d). 
  • After the disallowance of a third-party property owner’s request for return of wrongfully levied property under IRC 6343(b). 
  • Third party claims to property including alter ego and nominee liens. 

You can appeal to the employee’s manager and the manager will generally hold a conference with you. 

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 notice mean to me?

These letters advise you that a certain action has taken place or is being proposed. Therefore, you are entitled to exercise your CAP appeal rights. When you file a CAP appeal, the IRS will generally withhold collection action; however, it is not required by law to do so.

How did I get here?

You have a balance owed on your 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. A Notice of Federal Tax Lien (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 agreements;
  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?

If you have questions, you can contact the person shown at the top of the letter.

An Appeals officer will conduct an administrative review of your appeal. A decision is made and your case is returned to Collection or the originating division. You cannot appeal the decision made by the Appeals officer or file a petition to request judicial review by the U.S. Tax Court.

When you are returned to Collection you could review information regarding enforcement actions:

You could also review information regarding collection alternatives and resolutions:

Where can I get additional help?

Understanding your notice or letter

Get Help topics

Browse common tax issues and situations at TAS Get Help

If you think you’ll have trouble paying your taxes or the NFTL filing will cause economic hardship, it’s helpful to know what your options are to address your tax debt.

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.

Related Notices/Letters

  • Letter 3171, Notice of Federal Tax Lien Additional Filing,
  • Letter 3886, Notice of Special Condition NFTL Filing – Taxpayer,
  • Letter 3177, Special Condition Notice of Federal Tax Lien Filing – Third Party,
  • Letter 4052, Rejection of Proposed Installment Agreement,
  • Letter 2272-C, Installment Agreement Cannot be Considered/Extension to Pay Cannot be Considered,
  • Letter 5259, Notice of Installment Agreement Modification,
  • Letter 2975, Notice of Defaulted Installment Agreement Under IRC 6159(b),
  • CP 523, Default on Your Installment Agreement (IA) Notice – Intent to Terminate Your IA,
  • Letter 5603, Response to Certificate of Non-Attachment Request,
  • Letter 4025, Letter Advising of Action on Application for Discharge of Property From Federal Tax Lien,
  • Letter 4027, Advising of Action on Application for Subordination of Federal Tax Lien,
  • Letter 4711, Withdrawal Decision,
  • Letter 3975, Rejection of Request for Return of Levied Property,
  • Letter 3174, New Warning of Enforcement,
  • Letter 5603, Response to Certificate of Non-Attachment Request, and
  • Letter 1058, Final Notice Reply Within 30 Days

This list is not all inclusive.

Taxpayer Rights

The Right to Appeal an IRS Decision in an Independent Forum

Taxpayer Rights

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Taxpayer Files Collection Appeal Program (CAP) Request