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Last Updated: April 14, 2022

Taxpayer Requests Collection Appeals Program

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You have a balance on your tax account. If you disagree with an IRS employee decision regarding the collection of the tax, you may request a conference with the Collection manager. If you do not resolve your disagreement with the Collection manager, you may submit a verbal or written request for consideration by the IRS Independent Office of Appeals (Appeals) via Form 9423, Collection Appeal Request.

The Collection Appeals Program (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
  • Modification, or proposed modification, of an installment agreement
  • Denial of a request for a discharge, subordination, or withdrawal of a Notice of Federal Tax Lien
  • Disallowance of a taxpayer’s request for return of levied property
  • Disallowance of a third-party property owner’s request for return of wrongfully levied property
  • Third party claims to property including nominee and alter ego liens

CAP generally results in a quicker Appeals decision than a Collection Due Process (CDP) or Equivalent Hearing and is available for a broader range of collection actions. However, you cannot go to court if you disagree with the CAP decision. Under CAP, Appeals does not consider alternatives to the issue under appeals, but solely determines the appropriateness of the issue under appeal.

What does this mean to me?

The IRS has taken an action or has warned you action will be taken and you have been advised, verbally or in writing, that you are entitled to request an appeal using the CAP.

See Publication 594 and Publication 1660 for additional information on CAP.

For specifics on your particular notice, visit Understanding your IRS Notice or Letter.

How did I get here?

You disagreed with an IRS employee’s decision regarding the lien, installment agreement, levy, seizure or other decision.

What are my next steps?

The first thing to do is to check the return address to be sure it’s from the Internal Revenue Service and not another agency.

If it’s from the IRS, the notice will have instructions on how to respond and provide specific website link for you to visit for additional information located at the end of the notice or letter. Visit I got a notice from the IRS for further details including what to do if the notice is not from the IRS.

First and foremost, don’t ignore notices from the IRS. Even if you can’t pay the taxes you owe, responding to a notice before the due date could prevent a lot of trouble. For example, the IRS can issue a levy and take your property or assets (such as funds from a bank account, Social Security benefits, wages, your car, or your home). Be sure to keep your address up to date with the IRS so you receive all notices and letters.

If the IRS has already issued a CDP notice for that particular tax debt and you disagree with the IRS employee’s decision regarding any levy, seizure, or NFTL filing; you can appeal the decision. See Publication 594 and Publication 1660 for a full explanation of the CAP.

If you disagree with the notice, call the IRS at the toll-free number on the top right corner of your notice. Please have your paperwork (such as cancelled checks, amended return, etc.) ready when you call. See also Publication 5, Your Appeal Rights and How to Prepare a Protest If You Don’t Agree.

If you can’t pay the full amount by that date, you need to figure out what payment options might work for your situation, and act to set up a payment plan or other way to pay off your balance. For specifics, see I got a notice from the IRS on the TAS website.

Being proactive in addressing the tax debt may prevent additional penalty and interest charges and eliminate the need for the IRS to take action to collect the balance. For specifics, see I got a notice from the IRS on the TAS website and Revocation or Denial of Passport in Case of Certain Unpaid Taxes for further information.

You may represent yourself at CDP, CAP and other Appeals proceedings. Or, you may be represented by an attorney, certified public accountant, or a person enrolled to practice before the IRS. Also, you may be represented by a member of your immediate family, or in the case of a business, by regular full-time employees, general partners or bona fide officers. If you want your representative to contact us or appear without you and to receive and inspect confidential material, you must file a properly completed Form 2848 (no earlier than 10/2011 revision), Power of Attorney and Declaration of Representative. You may also authorize an individual to receive or inspect confidential material but not represent you before the IRS, by filing a Form 8821, Tax Information Authorization. These forms are available at your local IRS office, by calling 1-800-829-3676, or from IRS.gov.

If you believe you have an acceptable reason for interest or a penalty to be removed or reduced, you may complete Form 843, Claim for Refund and Request for Abatement, or send a signed statement to the IRS explaining your reason why. For specific instructions, see Notice 746, Information About Your Notice, Penalty and Interest.

You may wish to check your tax withholding to make sure you have enough taken from your payroll check each pay period or that you have made an accurate estimated tax payment to ensure you do not have a balance due at the end of the year. Too little can lead to a tax bill or penalty. Too much can mean you won’t have use of the money until you receive a tax refund.

Where can I get additional help?

Understanding your notice or letter

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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 3172 Notice of Federal Tax Lien and Your Rights to a Hearing Under IRC 6320,
  • 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,
  • Notice CP 501, Individual (IMF) Balance Due – First Notice,
  • Notice CP 503, Individual (IMF) Balance Due – Second Notice,
  • Notice CP 504, Final Balance Due Notice – 3rd Notice, Intent to Levy,
  • LTR LT11 – Final Notice — Notice of intent to levy and your notice of a right to a hearing,
  • Notice CP 90. Final Notice – Notice of Intent to Levy and Notice of Your Right to a Collection Due Process Hearing,
  • Notice CP 90C, Notice of Levy and Your Right to a Hearing,
  • Notice CP 92, Notice of Levy on State Refund Notice of Your Right to a Hearing,
  • Notice CP 242, Notice of Levy on Your State Tax Refund – Notice of Your Right to a Hearing,
  • Notice CP 77, Final Notice – Notice of Intent to Levy, Alaska Permanent Fund Dividend Levy Program (AKPFD),
  • Notice CP 297, Final Notice, Notice of Intent to Levy and Notice of Your Right to a Collection Due Process Hearing,
  • Notice CP 297A, Notice of Levy and Notice of Your Right to a Hearing – Federal Payment Levy Program (FPLP),
  • Notice CP 297C, Notice of Levy and Your Right to a Collection Due Process (CDP) Hearing,
  • 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,
  • Letter 1058, Final Notice Reply Within 30 Days,
  • LTR LT75 – Notice of Levy and your Rights to a Hearing,
  • Letter 2439, Notice of Jeopardy Levy and Right of Appeal, and
  • Notice CP 177, Intent to Seize Your Assets and Notice of Your Right to a Hearing.

This list is not all inclusive.

Where am I in the tax system?

Taxpayer Requests Collection Appeals Program

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