IRS Collection Appeals Program

If you are interested in appealing an IRS collection action such as a federal tax lien filing or a levy on your assets, you have two options generally available: the Collections Due Process Hearing and the Collection Appeals Program. The Collection Appeals Program (“CAP”), which this blog will be focusing on, can be an avenue to appeal based on:

  • Any federal tax liens
  • A notice by the IRS of its intent to levy (including notices you believe are erroneous)
  • Notice of the IRS’ intent to seize your property
  • Notice that your proposed installment agreement will be rejected
  • Notice that any existing installment agreements will be modified or terminated

This program does not apply to Offers in Compromise, appealing IRS penalties, audit reconsiderations, or most claims and jeopardy levies. Additionally, the CAP is not the appropriate venue to appeal an IRS decision not to release a lien on your property. 

Appealing to the Collection Appeals Program

Filling out and submitting Form 9243 to the IRS Collection Appeals Program is the first step in the CAP process if you are appealing a notice for a lien, levy, or property seizure. However, there are situations in which you should first call the IRS and attempt to resolve the issues over the phone. These circumstances include: 

  • If your property has already been seized. You must call the number listed on the letter the IRS sent informing you that they will not release the property you claim was erroneously seized. While on the phone, you need to request a conference with the Advisory Group Manager. If this hearing does not result in your property being released, you can then submit Form 9243. 
  • Any appeals requests related to installment agreements (rejection, modification, or termination). Call the number listed and try to resolve the issue over the telephone. If you are unable to do so, then submit Form 9243. 
When Must Your Submit Your Appeal to CAP?

There are strict time limits for submitting your appeal (Form 9423) to the Collection Appeals Program. For appeals related to installment agreements, you have: 30 days to appeal a proposed agreement or 76 days to appeal when you receive notice that the IRS intends to end your current installment agreement. For other CAP matters, the time limit often depends on whether or not you have participated in a Group Manager conference. 


Dealing with the IRS and its decision to place a lien or levy on your property or to seize your property outright is frustrating and somewhat scary. You do have appeal options, though. Weisberg Kainen Mark would be glad to review your case and help navigate you through the Collection Appeals Program. Call us at 305-374-5544 to see how we can help.

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Weisberg Kainen Mark, PL

As experienced trial lawyers with a passion for justice, our firm provides clients with compelling advocacy, attorney availability, and creative solutions to your tax or criminal law matters.

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