IRS Collection Appeals Program (CAP): Form 9423

The short answer

The Collection Appeals Program (CAP) lets the IRS Independent Office of Appeals review specified collection actions, including liens, levies, seizures and installment-agreement decisions. It can be faster and available in more situations than CDP. But you cannot challenge the underlying tax amount through CAP or obtain court review of the CAP decision itself.

CAP is therefore not a generic substitute for every tax appeal. Identify the action, the office handling it, the available procedure and the time to request review. Publication 1660 and the IRS's request-for-appeals guidance explain the action-specific rules.

When CAP can help

CAP can cover a proposed or filed Notice of Federal Tax Lien, a proposed or actual levy, a seizure, some denied lien remedies and denials involving return of levied property. It also covers rejection, proposed modification or modification, and proposed termination or termination of an installment agreement.

That breadth can matter when no new CDP notice has arrived or you need prompt review of a specific collection decision. A payment-plan dispute does not have to be forced into a lien-hearing form. Equally, the existence of CAP does not mean the same issue can be considered repeatedly through every appeal route.

For example, CP523 can involve default and proposed termination of an installment agreement. First identify the default and whether it can be corrected, then read the notice's appeal instructions. Do not send a generic lien dispute and expect it to preserve the payment-plan appeal.

CAP versus CDP and an equivalent hearing

CDP follows a qualifying lien or levy notice and, when timely requested, generally offers statutory levy protections and a route to Tax Court review. It can address the underlying liability only in limited circumstances.

An equivalent hearing is a separate late-request route tied to a prior CDP notice. It does not carry the same statutory levy prohibition, collection-clock suspension or right to review the hearing decision in Tax Court.

CAP reviews the collection action rather than the existence or amount of the tax. Its own decision has no direct judicial-review route. A timely CDP deadline does not automatically pause because you asked a manager to review the case or started a CAP discussion. Read both procedures before choosing, especially where overlapping rights exist.

Start with the correct Collection contact

For most lien, levy and seizure disagreements, first explain the problem to the Collection employee and request a Collection manager conference if unresolved. If contact has only been by notice or telephone, use the number on the notice and explain that you want to appeal the collection action.

For a revenue-officer case, contact the assigned officer and follow the manager-conference and written-request steps. Form 9423, Collection Appeal Request, is commonly used. Send it through the Collection office handling the case, not to an arbitrary Appeals address found online.

There is an important exception: the manager conference is recommended, but not required, before appealing installment-agreement rejection, modification or termination decisions. Do not let an effort to arrange an optional conference cause a missed appeal period. The IRS procedures expressly distinguish installment-agreement appeals.

Deadlines depend on the action

For a revenue-officer lien, levy or seizure dispute after a manager conference, Publication 1660 says to tell the officer or manager within two business days that you want CAP review to avoid resumption of collection. The written Form 9423 must be postmarked within three business days after the conference. Keep the two deadlines distinct.

If a requested manager conference produces no contact within two business days, the publication describes contacting Collection again or submitting Form 9423, recording the request date. It specifies a four-business-day receipt or postmark rule from the conference request in that situation because collection may resume.

A seizure also has a separate urgent rule: the appeal to the Collection manager must be made within ten business days after the Notice of Seizure is given or left at the home or business. Do not apply the ordinary manager-conference timeline as though it were the only seizure limit.

Installment-agreement rejection appeals generally have 30 days from the rejection letter. Proposed termination, actual termination and modifications have their own instructions and related periods; the publication describes an additional appeal period after termination, but not a duplicate second appeal where one was already taken before termination. Read the actual notice instead of treating every CAP case as either three days or 30 days.

What to put in the request

Identify the action, tax periods, decision date, manager contact and specific reason for disagreement. Attach the relevant notices and records. Explain a practical solution, such as recognizing a payment, correcting a default, considering a sustainable arrangement or reviewing a supported lien remedy.

Do not attempt to relitigate the tax assessment in CAP. If the amount itself is wrong, identify an appropriate separate correction or liability-review route. The tax debt inventory and communication log can help distinguish an accounting problem from a dispute over the enforcement decision.

For an unaffordable payment plan, compare the installment-agreement types and prepare the records needed for a revised proposal. A request for a smaller payment is stronger when the financial facts and proposed resolution are clear.

Collection during CAP

The IRS normally pauses the collection action being reviewed for the covered periods, but exceptions apply, including jeopardy and specified employment-tax situations. Installment-agreement levy protections have separate statutory rules. Do not assume every request stops all activity, releases an existing levy or protects periods outside the appeal.

Confirm what Collection has actually agreed to hold and preserve evidence of timely submission. A manager conversation and your own call notes are not the same as a processed appeal or a levy release.

What to do this week

1. Identify the exact action and the applicable notice or manager-conference date.
2. Ask the handling Collection office which CAP procedure applies and promptly request the required conference.
3. Use current Form 9423 where appropriate, explain the disagreement and propose a solution.
4. Meet the action-specific deadline and keep postmark or delivery evidence.
5. Continue to protect any separate CDP, deficiency, payment or court deadline.

Can I take a CAP loss to Tax Court?

Not simply to obtain judicial review of the CAP decision. Publication 1660 distinguishes that limitation from other rights that may independently exist. Obtain qualified advice about any separate remedy rather than assuming CAP creates a court appeal.

Is CAP a tax settlement?

No. CAP reviews a collection decision. An approved payment plan, accepted offer or other collection alternative has its own requirements and documentation. Asking for CAP does not establish that an alternative was approved.

Read the related chapter

The book provides broader context in the related chapter. For other options, browse the resolution option guides.

Official sources and review status

IRS sources checked October 30, 2026 (US Eastern time). Prepared by the TaxRZR editorial team; professional review is pending. This is general federal tax education, not a recommendation or eligibility decision for your case.

• Publication 1660: CAP procedures and installment-agreement appeals
• IRS: Preparing a request for appeals

See Source Notes for dated editorial changes. Verify current IRS instructions and your actual notice before acting.