IRS Collection Appeals Program: prepare a CAP request

The IRS Collection Appeals Program, or CAP, reviews a specific collection action that the IRS proposes or has taken. Start with the action, the office handling it and the result you want. An appeal of a proposed levy, an installment-agreement rejection and a denied request to return levied property need different records and timing checks.

Keep the collection decision, manager contacts, appeal request and eventual implementation together. The IRS collection-appeal instructions describe contact-specific routes. A notice or telephone case can allow an oral request; a Field Collection case uses a written request through the office or revenue officer involved.

Match the action and requested result to the right procedure

CAP asks whether the particular collection action is appropriate under the applicable law, rules and facts. It does not decide whether the underlying tax assessment is correct or negotiate every possible way to resolve the account. Within an actual installment-agreement appeal, however, Appeals can consider the appropriate monthly payment using the financial information.

Use the IRS CAP scope and exclusions to identify the issue before preparing a request:

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A Trust Fund Recovery Penalty dispute, offer-in-compromise appeal, penalty appeal, audit reconsideration and ordinary tax-refund or tax-abatement claim have separate procedures. CAP also excludes a refusal to release a lien. Assets under a court’s control and matters already in litigation require their own procedural review. Listing a collection problem does not establish that CAP can hear it.

For a lien application, first distinguish the specific lien certificate and property result. For a levy, establish whether bank funds are still held or have already reached the IRS. The Collection manual explains that once the IRS has received a levy payment, the original levy appeal route is no longer the same task: an administrative return claim, and potentially an appeal of its denial, may be involved. Do not wait for money to move while assuming an unchanged appeal route.

Preserve any separate notice-based hearing right

CAP and Collection Due Process, or CDP, are different procedures. A CAP request does not serve as a CDP request or extend its filing period. If you received LT11 or Letter 1058, or another notice granting CDP rights, keep the notice and its response date in a separate entry. The CDP request and evidence guide covers that notice-by-notice task.

The Collection manual discusses requesting both procedures. It also says that an issue decided in a CAP appeal completed before a CDP request, with your meaningful participation, may be excluded from the CDP hearing unless new information is presented; Appeals determines that question. The Appeals manual requires a choice when both requests concern the same proposed levy or lien-filing event, with specific consequences for a CDP withdrawal. These are not a promise of two concurrent hearings. Preserve every request and response, and resolve the procedural choice before signing a withdrawal. Choosing CAP simply because it is described as faster can give up an important review right.

Identify the office and make a manager-contact record

Keep the notice number, taxpayer or property owner, tax periods, disputed property and handling office on the first page of your record. Then identify the actual contact route:

• Only a notice or telephone contact. Call the number on the notice or the number identified by the IRS employee. Explain the action, disagreement and proposed solution. If it remains unresolved, ask for a Collection manager. Publication 1660 describes an oral pathway in which an unresolved manager decision is forwarded to Appeals without a written request.
• An Automated Collection System or Accounts Management case. Current Appeals procedures also allow oral CAP requests. Record the employee, office, requested manager discussion and what will be forwarded. A manager conference generally precedes forwarding a lien or levy case.
• Contact with a revenue officer. Start with that officer and request the manager conference. Form 9423, Collection Appeals Request, is the recommended written format for Field Collection. The Appeals manual says other written CAP requests will be honored, but the form helps organize the required facts.
• An installment-agreement decision. A manager conference is encouraged but is not mandatory for CAP appeals of a rejected, modified, proposed-for-modification, terminated or proposed-for-termination agreement. Use the decision’s own appeal instructions rather than delaying for a conference that is not required.

Submit through the Collection office involved, using the destination and permitted method confirmed for that case. Do not send the request directly to an Appeals office or assume there is one national Form 9423 mailing address. The IRS manual’s Electronic Case Receipts system and Form 15044 concern internal IRS forwarding; they do not establish a taxpayer online filing service.

Record events rather than one guessed deadline

The current Collection manual says most CAP situations have no universal request deadline. That does not preserve a collection pause indefinitely, prevent the stage changing or override the seizure and installment-agreement exceptions.

For the ordinary Field Collection lien, levy or seizure pathway, record these events:

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Form 9423 directs you to notify Collection within two business days after the manager conference that you plan to submit the form, and to have it received or postmarked within three business days of that conference, or collection action may resume. If the form was already provided, record that fact rather than assuming a second submission is needed.

If a manager or designee has not contacted you within two business days of your conference request, the form describes contacting Collection again or submitting Form 9423. When submitting it, put the original conference-request date and the lack of contact in block 15. The form says it should be received or postmarked within four business days of the original request, as collection action may resume. Missing a callback is not approval of the appeal or an extension of another notice deadline.

There is an important distinction between accepting a later request and continuing a collection pause. The newer Collection manual allows consideration of a request received in a reasonable time after the conference, giving ten business days as an example. It also says the stay is no longer required when the three-business-day postmark instruction is missed. An Appeals manual note instead refers to a two-business-day receipt condition for the stay, alongside its three-business-day main instruction. Because those published descriptions differ, do not rely on a last-day assumption about protection. Submit promptly, retain evidence and ask the handling office to confirm the actual collection status. The later-request discussion is not ten extra protected days.

Apply seizure and installment-agreement exceptions separately

After a seizure, the sources specify an 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. Preserve how and when that happened. An imminent sale or perishable property can change what can still be done; this guide does not calculate a personal last filing day.

Installment-agreement appeals have separate 30-day rules tied to the actual decision:

• Formal rejection: a 30-day appeal period requiring a timely postmark. A failed online application alone is not proof of a formal rejection.
• Modification: 30 days from the proposed modification to appeal; the manual also allows appeal before the end of the 30-day period starting the day after the modification takes effect. Requesting a hearing before modification does not create another appeal of that same decision afterward.
• Proposed termination: 30 days from the notice of intent to terminate. The actual-termination appeal period starts the day after the date the notice says termination takes effect and lasts 30 days. Appealing the proposed termination does not create a second appeal after it takes effect.

Use the formal payment-plan rejection guide or the defaulted or terminated agreement guide for the relevant stage, correction and appeal record. Keep the notice date, proposed effective date and any prior appeal together; do not restart a period from the day you opened the mail.

Connect your disagreement to evidence and a proposed result

On Form 9423, identify the action you disagree with, explain why and state the solution you propose. Keep the explanation specific enough to compare with the actual IRS decision. A request to change a levy should identify that levy and its effects, rather than simply asking for all tax debt to disappear.

Build a short action-to-request record:

1. Who and what are affected? Name the taxpayer or property owner, relevant periods, property, decision and proposed or completed action. Include all pages of the relevant notice or denial.
2. What should change? State the precise result requested and its connection to the disputed action. Separate any other open application, claim or hearing request.
3. What supports the request? List the documents and the fact each establishes. Depending on the issue, these can include financial statements and supporting records, payment postings, ownership documents, a lien-certificate application or the original property-return claim and denial.
4. What happened before submission? Attach the dated contact and manager-conference record, including an unresolved outcome or missed-contact facts.
5. What was sent and received? Retain an identical packet and sending evidence. Record later requests for information, their due dates and your response.

Keep supporting material consistent and disclose relevant facts. You may present your own case. If an authorized representative will appear without you, the form instructions require a properly completed Form 2848, Power of Attorney and Declaration of Representative.

Confirm collection status while the appeal is handled

The Appeals manual describes a policy suspension of the disputed lien, levy or seizure collection action while that CAP case is in Appeals. Collection can continue enforcement when delaying would put collection at risk, including situations involving dissipating assets or accumulating unpaid federal tax deposits. Installment-agreement rejection and termination matters have separate statutory levy restrictions and exceptions.

Ask which action and periods are covered, when the request was forwarded and what Collection has actually instructed others to do. Filing a request is not confirmation that an existing levy was released, that a bank retained funds or that an employer stopped withholding. Track an existing wage levy through its separate release record. Do not treat CAP as an account-wide freeze or as stopping interest on unpaid tax.

Prepare for the Appeals contact and any qualifying file access

Record when Collection received the request, when it was forwarded and when the assigned Appeals employee received it. The manual’s ordinary five-business-day completion goal starts with that employee’s receipt, not when you mailed Form 9423. Complicated lien, installment, seizure or claim matters generally have a 15-business-day goal. These are internal goals, not a promised decision date. Most CAP matters are handled by telephone or correspondence.

Ask the Appeals contact about access to the nonprivileged disputed-issue file before the initial conference. Current case-file procedures define qualifying specified taxpayers using the original filed return for any one disputed year: adjusted gross income of $400,000 or less for a natural person, or gross receipts of $5 million or less for another entity. The manual treats a disputed substitute-for-return year or unclear qualifying status as specified, while some matters without a relevant required return fall outside that definition. Record the basis discussed with Appeals. These are file-access criteria, not eligibility limits for CAP itself.

For a qualifying requested file, the normal rule provides access at least 10 calendar days before the initial conference. You may elect an earlier conference after receiving access; it cannot occur before you receive the requested file. Privileged material and documents you supplied to the IRS are excluded from this access right. Keep your own submission copies.

Enter the access request, delivery date, conference date and any election in the ledger. File access can change the scheduling and five-day processing goal. CAP does not necessarily produce a standard acknowledgment letter, so preserve the actual contacts and follow up through the handling office rather than assuming silence establishes receipt or a decision.

Retain the decision and verify the directed action happened

Keep the written outcome with the original action and requested result. A CAP decision is generally binding on you and Collection, subject to the documented exceptions. Later default can release Collection from an agreement’s terms; material misrepresentation or failure to disclose material facts can make an agreement voidable.

Record whether the decision sustains the action or directs a change, who must implement it and what evidence confirms completion. If the result calls for a levy release, lien action, agreement correction or reconsideration of a denied claim, the decision and the actual implementation are separate entries. Keep the remaining balance, current payment duties and other unresolved notices visible.

You cannot obtain judicial review of the CAP decision itself. Form 9423 also explains that other administrative or judicial proceedings may remain available for the underlying issue, such as certain third-party wrongful-levy matters. Those proceedings have their own requirements and dates. A CAP decision does not settle every possible claim or restart its filing period.

Sources and scope

Sources checked on November 13, 2026 include the IRS appeal-request instructions, Form 9423 and Publication 1660, linked above; IRM 8.24.1, Collection Appeals Program; IRM 5.1.9, Collection Appeal Rights; and the current case-file access procedures. The manuals contain action-specific rules and differing descriptions of the stay timing, identified above. This guide organizes records and procedures; it does not determine a person’s eligibility, property rights, collection protection or filing deadline.