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Published:   |   Last Updated: October 12, 2023

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 can submit a written request for consideration by the IRS Independent Office of Appeals (Appeals) preferably via Form 9423, Collection Appeal Request if you have been contacted by a Revenue Officer or verbally or in writing if your only contact with the IRS has been via notice or telephone.

Instances in which you can pursue the Collection Appeals Program (CAP) include, but are not limited to:

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

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

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 appeal using 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 a lien, installment agreement, levy, seizure or other decision.

What are my next steps?

If you disagree with the IRS employee’s decision concerning lien or levy, or proposed lien or levy actions, you can call the IRS at the telephone number on your notice or the number you spoke to the employee at.  Be prepared to explain which action(s) you disagree with, why you disagree, and a proposed solution.  If you cannot reach an agreement, advise the employee you would like to appeal.  The employee must refer you to their manager.  If the manager is not available to speak immediately, they should return your call within 24 hours.

If you request an appeal after IRS makes a seizure, you must appeal to the Collection manager within 10 business days after the Notice of Seizure is provided to you or left at your home or business with the manager.

If the manager sustains the employee’s decision, you can submit a request for Appeals consideration verbally, in writing, or via Form 9423 to the IRS employee within three business days of meeting with the manager.  If you have been in contact with a Revenue Officer use Form 9423 for CAP appeal requests.

If possible, advise the employee or manager that you will be filing a CAP appeal within two (2) days of the manager’s conference. Otherwise collection action may resume. 

If you request a conference and are not contacted by a manager or his/her designee within two (2) business days of making the request, you can contact Collection again or submit Form 9423. If you submit Form 9423, note the date of your request for a conference in Block 15 and indicate that you were not contacted by a manager. The Form 9423 should be received or postmarked within four (4) business days of your request for a conference as collection action may resume. 

If you disagree with the IRS employee’s decision concerning rejection or termination of an installment agreement, you will have 30 days from the date of the notice to appeal.  You can contact the employee’s manager to request a conference, but a manager conference is NOT required to be attempted for appeals involving installment agreements; however, it is encouraged one be held whenever possible. If the manager sustains the employee’s decision, you can submit a request for Appeals consideration in writing, via Form 9423.  Your written request must be postmarked within 30 days from the date of the notice to be considered.

If you disagree with the proposed modification or modification of your installment agreement, please follow the directions under the section of your notice entitled, “How do you appeal the termination of an installment agreement?”

You may represent yourself 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 the IRS 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.

Under CAP, Appeals does not consider alternatives to the issue under appeal, nor will it consider the existence or amount of your tax liability, but solely determines the appropriateness of the issue under appeal. Appeals’ administrative decisions are final and there is no right to judicial review in court if you disagree with the decision. If your issue is not resolved through CAP you can explore “I Need Help Resolving My Balance Due” on the TAS website.

Never forward your request for an Appeals conference directly to Appeals. It must be submitted to the office which took the action on your installment agreement. 

Where can I get additional help?

Understanding your notice or letter

Get Help topics

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