Form 9423 allows taxpayers to appeal certain IRS collection actions—lien filing, levy, seizure, or installment-agreement rejection, modification, or termination—through the Collection Appeals Program (CAP). Unlike a Collection Due Process (CDP) hearing requested on Form 12153: Request a CDP or Equivalent Hearing, CAP does not permit you to challenge the existence or amount of the underlying tax liability, and the Appeals Office decision is final with no judicial review available. CAP provides review by the IRS Independent Office of Appeals, with a Collection-manager conference required first for certain actions. It does not replace separate CDP or court procedures.
Routing and deadline logic
The correct routing and deadline depend on which collection action you are challenging. For liens, levies, or seizures, the IRS requires you to first request a conference with a Collection manager. If that conference does not resolve the issue, notify Collection within two business days that you intend to file Form 9423, then submit the completed form within three business days after the conference, or collection action may resume. If you request a manager conference but no manager or designee contacts you within two business days, contact Collection again or submit Form 9423 directly; in that scenario, submit the form within four business days of your original conference request and document the requested-conference date and lack of contact in block 15 of the form. For a post-seizure appeal, you must appeal to the manager within ten business days after the notice of seizure is provided to you or left at your home or business.
For rejected installment agreements, proposed or actual modifications, or proposed or actual terminations, send Form 9423 to the IRS office or revenue officer who took the action within 30 calendar days of the notice. A manager conference is recommended but not required for installment-agreement disputes. Never mail Form 9423 directly to the Appeals Office regardless of the type of action; Collection or the originating office must forward it internally. Do not apply a blanket three-day deadline to every CAP case—installment-agreement appeals follow a 30-day calendar window, not the shorter business-day deadlines that apply to lien, levy, and seizure disputes.
Completing block 15 and attachments
Block 15 is the substantive core of your appeal. Identify the specific collection action you are challenging, explain your grounds for disagreement, and propose a concrete alternative solution. Attach copies—not originals—of the notice or letter that triggered the appeal, prior correspondence with Collection, financial statements if relevant to your proposed resolution, and any other documents that support your position. If you are represented, include a valid power of attorney or Form 2848. Focus your explanation on the challenged collection action, your grounds for disagreement and your proposed solution; CAP does not provide a route to dispute the underlying tax liability. If you initially requested a manager conference that did not occur, note the date of your request and the absence of contact in block 15 to protect your timeline.
Collection activity during review
Collection action ordinarily stops while CAP is pending, but the suspension is not absolute. The IRS may proceed if it determines that collection or the amount owed is at risk. Do not assume automatic protection in every case. If you need certainty that no levy or seizure will occur during the appeal, request confirmation in writing from the revenue officer or manager handling your case. CAP generally produces a quicker decision than CDP but offers narrower procedural safeguards, so assess whether the timeline and limited scope meet your needs before choosing this route over a CDP hearing or other remedy such as IRS Audit Reconsideration: Prepare an Evidence Packet if the underlying assessment itself is incorrect.
| Collection action | Manager conference required | Deadline or required first step | Where to send Form 9423 |
|---|---|---|---|
| Lien, levy, seizure (general) | Yes | Three business days (notify within two) | Collection office that issued notice |
| Seizure (post-notice) | Yes, to manager | Ten business days from notice | Manager who issued seizure notice |
| Manager unresponsive | Attempted | Four business days from request | Collection office; document in block 15 |
| Installment agreement (rejected, modified, terminated) | Recommended, not required | 30 calendar days | Office or officer who took the action |
Use the current Form 9423 instructions for action-specific requirements and Publication 1660 to compare CAP with CDP.
Pre-filing checklist
- [ ] Confirm the action is CAP-eligible (lien, levy, seizure, or installment-agreement action, not an audit adjustment or refund claim)
- [ ] Request a Collection manager conference if required for your action type
- [ ] Note the conference date and outcome; if unresolved, notify Collection within two business days
- [ ] Calculate the correct deadline—three or four business days for lien/levy/seizure, 30 calendar days for installment agreements
- [ ] Complete the applicable taxpayer, representative and tax details, and identify the challenged collection action in block 14
- [ ] Draft a clear block 15 statement: action challenged, grounds, proposed solution
- [ ] Attach copies of the triggering notice, prior correspondence, financial documents, and representation authority
- [ ] Mail or deliver to the originating Collection office or revenue officer, not directly to Appeals
- [ ] Retain proof of mailing or delivery and a complete copy of the submitted package
- [ ] If collection activity resumes before review, contact the revenue officer immediately to confirm receipt and status
Can I use Form 9423 to dispute the tax amount itself?
No. CAP reviews only whether the collection action is appropriate given your circumstances and compliance history. If you believe the assessment is incorrect, pursue IRS Audit Reconsideration: Prepare an Evidence Packet, file an amended return, or submit Form 843: Prepare a Refund or Abatement Request depending on the type of error. CAP does not reopen the underlying liability.
What happens if I miss the CAP deadline?
The IRS may resume collection action immediately. If you receive a CDP notice later, you can request a CDP hearing on Form 12153, but its deadline depends on the qualifying lien or levy notice and the applicable CDP rules. Missing the CAP deadline does not eliminate all appeal rights, but collection may resume and the available review routes must be checked for the specific action.
Is the CAP decision binding or can I appeal further?
The CAP decision is final and not subject to judicial review. If you disagree with the Appeals Office determination, you have no further administrative or court appeal of the CAP decision itself. Separate legal remedies—such as a later CDP hearing, refund suit, or wrongful-levy claim—may exist depending on your situation, but CAP itself provides no second layer of review.
For tax firms
Track CAP deadlines in your case-management system by action type to avoid forfeiting the appeal window.
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