IRS Form 9423: How the Collection Appeals Program Works

What is IRS Form 9423 used for?

IRS Form 9423 requests review of certain collection actions through the Collection Appeals Program. It can cover specified liens, levies, seizures, denied requests involving levied property, and installment agreement decisions. The form asks what action is disputed, why it is disputed, and what resolution is proposed.

CAP is an administrative review by the IRS Independent Office of Appeals. The IRS guidance for preparing an Appeals request describes CAP as available for a broad range of collection actions and generally resolved quickly. The guidance also states that a CAP decision does not carry a right to court review.

The form is about the collection action, not a general request to reduce or recalculate the assessed tax. Publication 1660, Collection Appeal Rights, says CAP cannot be used to challenge the existence or amount of the tax liability. A proposed resolution might involve collection treatment, supporting records, or a requested change to the action, but Form 9423 is not a substitute for an audit protest, amended return, refund claim, or deficiency petition.

The request can come from a taxpayer or, for some collection actions, a third party whose property is affected. The printed instructions include denials involving return of levied property and certain third party property claims. Those disputes can involve rules beyond the ordinary taxpayer CAP sequence, so the exact denial letter and its stated route remain important.

Which collection actions can Form 9423 cover?

Form 9423 can cover a proposed or filed federal tax lien, a proposed or completed levy, a seizure before sale, certain denied lien certificate requests, certain denied property return requests, and rejection, modification, or termination of an installment agreement. The applicable facts and IRS correspondence control eligibility.

The checkboxes on the current form list federal tax lien, levy or proposed levy, seizure, rejection of an installment agreement, termination of an installment agreement, and modification of an installment agreement. The instructions add more detail than the checkbox labels, which is why the reverse side should be read with the front page.

For a lien, Publication 1660 says CAP can be available before or after an NFTL filing and at the first or a later filing. It also lists denied requests to withdraw an NFTL and denied applications for discharge, subordination, or non-attachment. A lien hearing under Collection Due Process has a different trigger and review path, even when both procedures concern the same filing.

For a levy, CAP can address action before or after the levy. Publication 1660 also discusses review after the IRS denies a request to return levied property. A seizure appeal can arise before or after seizure, but the publication limits the described CAP route to the period before the property is sold. The dates and action status therefore belong in the factual explanation.

Form 9423 is not the general appeal form for a rejected offer in compromise, an examination change, a penalty denial, or a proposed trust fund recovery penalty. The IRS forms and publications page for appeal rights organizes those matters under separate procedures and forms.

What happens before Form 9423 is filed?

A lien, levy, or seizure dispute generally starts with the IRS employee and a request for a Collection manager conference. If a manager conference does not resolve the issue, Form 9423 can request Appeals review. Installment agreement disputes do not require that conference, although the IRS strongly recommends one when possible.

When a revenue officer is involved, the sequence in the form instructions begins with a conference request to the employee's manager. The manager reviews the disagreement before the case goes to Appeals. If the dispute remains unresolved, the person seeking review tells Collection that a CAP appeal will be submitted, completes Form 9423, and returns it to the Collection office involved.

The route is slightly different when the only collection contact has been a notice or telephone call. Publication 1660 directs the person to call the number shown on the notice, explain the disputed action, and offer a solution. If the employee and manager do not resolve the issue, the case can be forwarded to Appeals without a written request. The live IRS Appeals page also directs notice based contacts to the number on the notice.

For an installment agreement rejection, modification, or termination, the Form 9423 instructions state that a manager conference is not required. They strongly recommend one whenever possible. The appeal is directed to the office or revenue officer that took the installment agreement action, and the applicable 30 calendar day period differs from the short business day sequence used after a lien, levy, or seizure manager conference.

A manager conversation is not a reason to ignore another date printed on an IRS notice. A person can have more than one collection event, and CAP timing does not silently extend a separate Collection Due Process deadline. The notice code, the action being challenged, the manager conference date, and the proposed resolution should remain separate entries in the case record.

• Identify the IRS employee, office, or notice telephone number connected to the action.
• Record the date a manager conference was requested and the date it occurred.
• State the specific collection action and the tax type and periods involved.
• Gather the notice, correspondence, payment records, and other documents supporting the disagreement.
• Describe a proposed resolution that addresses the collection problem rather than only restating the objection.

What are the Form 9423 filing deadlines?

Form 9423 does not have one universal deadline. After a manager conference about a lien, levy, or seizure, notice of intent to appeal is due within two business days and the form within three business days. Other rules apply after manager nonresponse, seizure, or an installment agreement decision.

The short periods appear on the second page of Form 9423. After an unresolved manager conference about a lien, levy, or seizure, the Collection office should be told within two business days that a CAP request is planned. The form must then be received or postmarked within three business days after the conference, or collection action may resume.

If a manager or designee does not make contact within two business days after a conference request, the instructions allow another contact with Collection or submission of Form 9423. Block 15 should state the conference request date and the lack of manager contact. The form should be received or postmarked within four business days after that request.

Installment agreement timing deserves special care because rejection, proposed termination, actual termination, and modification do not always arise on the same date. Publication 1660 says a proposed agreement rejection appeal is due on or before the thirtieth day after the rejection letter. For a proposed termination, the publication describes a 30 day period before termination and another 30 day appeal period after termination, while preventing a duplicate appeal of the same decision.

How is Form 9423 completed?

Form 9423 identifies the taxpayer, representative, contact details, tax type, tax periods, amount due, and collection action being appealed. Block 15 is the core explanation. It should state why the collection action is disputed, propose a way to resolve the tax problem, and identify supporting documents attached to the request.

Blocks 1 through 10 identify the taxpayer, representative, identification number, telephone numbers, and address. A representative who will act under a power of attorney attaches Form 2848. The signature block permits the taxpayer or an authorized representative to sign, and the declaration says the request and attachments are true, correct, and complete to the best of the signer knowledge and belief.

Blocks 11 through 13 identify the tax form, periods under appeal, and amount due. These entries connect the CAP request to the correct account segments. A notice might cover more than one period, so a list can be clearer than a general phrase. The values can be copied carefully from the relevant correspondence and checked against any account record being used.

Block 14 identifies the action. More than one checkbox can apply, but each selected action should connect to the explanation. For example, a lien dispute and a levy dispute may involve different dates and documents. Combining them under one vague sentence can make it harder to see which fact supports which requested change.

Block 15 asks two questions: why the person disagrees with the selected collection action, and how the tax problem would be resolved. A useful explanation can separate facts, disagreement, proposed resolution, and attached proof. It can include an additional page when the form space is not enough. The form expressly permits attachments and says new information will generally be sent to Collection for review and comment before Appeals considers the response.

The form contains IRS use only blocks for the revenue officer and Collection manager. Those blocks are not part of the taxpayer explanation. Keeping a complete copy of the signed form, every attachment, and the delivery proof preserves the exact material submitted if Appeals later asks about new information or Collection comments.

Where is Form 9423 sent?

Form 9423 goes to the Collection office involved in the disputed action, or to the office or revenue officer that made the installment agreement decision. It should not be mailed directly to the Independent Office of Appeals. Collection receives the request, reviews it, and forwards an unresolved case for Appeals consideration.

Both the form instructions and the live IRS Appeals page repeat this routing rule. A lien, levy, or seizure request goes to the Collection office involved in that action. An installment agreement request goes to the office or revenue officer that rejected, modified, or terminated the agreement. The denial letter for a property return request identifies the Advisory Group office involved in that decision.

There is no single universal mailing address printed on Form 9423. The correct route comes from the contact handling the action, the relevant notice, or the decision letter. A generic Appeals address is not the right first destination. The IRS warns that sending a protest directly to Appeals can delay processing and may prevent consideration when a deadline applies.

A delivery record is especially useful because the filing rules use received or postmarked language in different situations. The record can include the form, attachments, destination, date, and confirmation. When Collection provides a fax or other approved submission route, the confirmation can be saved with the signed copy and the notice that supplied the contact information.

The IRS Collection office gets the first opportunity to consider the request and any new information. If the matter remains unresolved, Collection forwards it to Appeals. Direct delivery to Appeals skips that required first review and does not create extra time under the short CAP deadlines.

Does filing Form 9423 stop collection?

Collection action is normally paused for the disputed tax periods while a timely CAP appeal is considered, but the pause is not absolute. The IRS may continue when it believes collection is at risk, and special levy exceptions can apply. A late or misrouted request can also allow collection activity to resume.

The Form 9423 instructions say the IRS will normally stop the collection actions under dispute until the appeal is settled, unless collection or the amount owed is considered at risk. Publication 1660 states a similar general rule for lien, levy, and seizure cases and identifies an additional exception for a business meeting the criteria for a Disqualified Employment Tax Levy.

The word normally is important. A CAP request is not an unconditional promise that every collection action will stop. The disputed periods, the timeliness of the request, the particular action, and the risk exceptions affect the result. Filing the form also does not erase the balance, remove accrued charges, or approve the proposed resolution merely because it was requested.

Installment agreement cases have their own protection. Publication 1660 says the IRS cannot levy during the 30 days after rejection or termination of an agreement. When a timely appeal is made in that period, levy is prohibited until the appeal is completed unless collection is in jeopardy. The notice and agreement status determine which period is running.

A CP523 installment agreement default notice can signal a proposed termination and provides the facts and date that need review. The form does not replace the notice. It is the CAP request connected to the disputed agreement action, while the notice identifies the account event and contact route.

How is CAP different from Collection Due Process?

CAP covers more kinds of collection actions and generally produces a faster administrative decision, but it does not permit a challenge to the underlying tax or court review of the CAP decision. Collection Due Process follows qualifying lien or levy notices, usually uses Form 12153, and can preserve Tax Court review after a timely request.

CAP and Collection Due Process are separate procedures. They can both concern liens or levies, but they differ in trigger, timing, issues, form, collection effects, and review after Appeals. Form 12153 requests a Collection Due Process or Equivalent Hearing. Form 9423 requests CAP review when a written CAP request applies.

A CP504 collection notice is not itself the usual final levy notice that opens the standard pre-levy CDP route. An LT11 final levy notice and Letter 1058 generally contain Collection Due Process hearing language. A lien filing notice, commonly Letter 3172, can provide a separate lien hearing opportunity.

The form named on a familiar website should not override the actual IRS correspondence. A notice may offer CDP, CAP, a manager conference, or another protest process. The Form 12153 guide explains the distinct hearing request and Equivalent Hearing route. Form 9423 stays focused on the narrower CAP review addressed here.

Using CAP does not convert a non-CDP notice into a CDP notice, and missing a CDP date is not cured automatically by submitting Form 9423. Publication 1660 also notes that issues considered in one administrative or judicial hearing can affect whether they may be raised later. The notice wording and procedural history therefore matter together.

What happens after the Collection office receives the form?

Collection first reviews the request and any new information. If the dispute remains unresolved, the case is forwarded to the Independent Office of Appeals. Appeals can ask Collection to verify new material, share Collection comments for a response, and then issue a binding CAP decision based on the administrative record.

The Independent Office of Appeals is separate from the Collection office that initiated the action. Publication 1660 describes safeguards for that independence, including restrictions on certain one sided communications about the strengths and weaknesses of a case. At the same time, the form says Appeals generally asks Collection to review and verify new information submitted with the request.

That verification step is not hidden from the person requesting review. Form 9423 says Collection comments will be shared and an opportunity to respond will be provided. Clear labels on attachments can make the factual sequence easier to follow when the material moves between Collection and Appeals.

A person may appear without a representative or may use an eligible representative. The form identifies attorneys, certified public accountants, and enrolled agents, and it requires a properly completed Form 2848 when a representative will appear without the taxpayer. Publication 1660 describes some additional authorized representatives and distinguishes representation from permission merely to receive information.

The official guidance does not promise a fixed number of days for every CAP decision. It says CAP generally produces a quicker decision, but the record, requested information, and action can vary. A third party estimate should not replace a live request for status through the contact handling the matter.

Once Appeals decides the CAP case, the decision is binding on both the person who requested review and the IRS. Form 9423 says there is no judicial review of the CAP decision itself. It also notes that some issues can have another administrative or judicial route, such as a qualifying third party wrongful levy action. That statement does not turn CAP into a general gateway to court.

Why does the IRS notice still control the next step?

The notice identifies the collection event, account periods, response date, contact office, and available appeal route. Form 9423 supplies a CAP request, but it does not replace the notice or change a separate deadline. Reading the code, date, action, and appeal language together prevents different procedures from being confused.

A CAP request often appears in the middle of a longer collection sequence. Earlier balance notices explain the amount due and payment options. Later notices can warn of levy, report an installment agreement default, or provide a formal hearing opportunity. The same account can therefore have several documents with different legal and administrative functions.

A simple tracking sheet can record the notice code, notice date, tax periods, response date, IRS contact, disputed action, manager request date, conference date, submission date, delivery confirmation, and current status. That record helps keep a three business day CAP filing period separate from a 30 day notice period or an installment agreement appeal period.

Tax Panic can identify supported notice codes and explain what the document usually means in plain language. The Android app is free to start in the Google Play Store. It does not access IRS accounts, calculate a filing deadline, complete Form 9423, choose between CAP and CDP, or represent anyone before the IRS.

The safest general reading order is the actual IRS notice first, the current form instructions second, and the official procedure page third. That order keeps the article in its proper role as an educational map. The controlling details remain the live IRS documents and the facts recorded in the collection file.