What Is IRS Form 9423 and the Collection Appeals Program?

Updated July 20, 2026 • Educational overview

What is IRS Form 9423?

IRS Form 9423 is titled Collection Appeal Request.

The form may be used by a taxpayer or, in certain cases, a third party whose property is affected by an IRS collection action to request review through the Collection Appeals Program.

Form 9423 does not automatically eliminate the tax balance, release property, cancel a federal tax lien, or approve a payment arrangement.

Instead, it asks the IRS Independent Office of Appeals to review a specific collection action or collection decision.

What is the Collection Appeals Program?

The Collection Appeals Program, commonly abbreviated as CAP, is an administrative process for challenging certain IRS collection actions.

CAP is generally intended to provide relatively prompt review of a specific collection action or decision.

Examples may include disputes involving:

• A proposed levy
• A levy that has already occurred
• A seizure of property
• A proposed seizure
• A Notice of Federal Tax Lien filing
• A proposed Notice of Federal Tax Lien filing
• The denial of a request to release a lien
• The denial of a request to discharge property from a lien
• The denial of a request to subordinate a federal tax lien
• The rejection of an installment agreement
• The proposed termination of an installment agreement
• The modification of an installment agreement
• The denial of a request to release levied property
• The denial of a request to return levied property

Whether CAP is available depends on the collection action, the account history, the timing of the appeal, and the applicable IRS procedure.

What IRS collection actions may be appealed?

Form 9423 identifies several types of collection actions that may qualify for review.

Federal tax lien issues

A taxpayer may be able to request CAP review involving:

• The filing of a Notice of Federal Tax Lien
• A proposed filing of a Notice of Federal Tax Lien
• A denial of a request for lien withdrawal
• A denial of a request for lien subordination
• A denial of a request to discharge specific property from a lien

Levy issues

CAP may be available before or after certain levy actions.

Examples may include:

• A proposed bank levy
• A wage levy
• A levy against other income
• A levy against business receivables
• A denial of a request to release a levy
• A denial of a request to return levied property

Seizure issues

A taxpayer may be able to appeal a proposed seizure or, subject to strict timing requirements, a seizure that has already occurred.

Seizures can involve vehicles, business property, real estate, equipment, or other property.

Installment-agreement issues

CAP may also be available when the IRS:

• Rejects a proposed installment agreement
• Proposes terminating an existing installment agreement
• Proposes modifying an existing installment agreement
• Terminates an installment agreement

The taxpayer should review the applicable IRS letter carefully because the available appeal process and deadline may be stated in the notice.

CAP compared with Collection Due Process

The Collection Appeals Program is different from a Collection Due Process hearing.

The correct appeal process depends on the notice, collection action, deadline, tax period, and procedural history.

Submitting the wrong form or missing the applicable deadline may affect the taxpayer’s rights.

Does Form 9423 stop IRS collection activity?

Collection activity may be suspended while certain CAP issues are being considered, but taxpayers should not assume every collection action will automatically stop.

The result may depend on:

• The type of collection action
• Whether the appeal was submitted on time
• Whether collection is considered at risk
• Whether the requested manager conference occurred
• Whether the appeal involves a proposed or completed action
• The specific tax periods listed in the request

Because timing is critical, the taxpayer should follow the IRS notice and Form 9423 instructions exactly.

How does the Form 9423 appeal process work?

The process may vary depending on whether the taxpayer is dealing with an IRS revenue officer, the Automated Collection System, or another collection function.

Step 1: Discuss the issue with the IRS collection employee

The taxpayer should explain why the proposed or completed action is incorrect, inappropriate, or unnecessarily intrusive.

The taxpayer may also propose an alternative method for resolving the tax debt.

Step 2: Request a conference with the collection manager

If the taxpayer cannot resolve the issue with the collection employee, the taxpayer may generally request a conference with that employee’s manager.

The manager reviews the collection action and the taxpayer’s concerns.

Step 3: Complete Form 9423

If the taxpayer disagrees with the manager’s decision, the taxpayer may complete Form 9423.

The form should clearly identify:

• The collection action being appealed
• The tax periods involved
• The reason the taxpayer disagrees
• The proposed solution or collection alternative

Step 4: Submit the form promptly

Some CAP deadlines are extremely short.

For certain field-collection cases, IRS instructions generally require the taxpayer to submit Form 9423 promptly after the manager conference.

The taxpayer should use the exact deadline and submission instructions provided by the IRS employee, manager, notice, and current Form 9423 instructions.

Step 5: Appeals reviews the case

The IRS collection function generally forwards the appeal request and relevant case information to the Independent Office of Appeals.

An Appeals employee may contact the taxpayer or authorized representative to discuss the dispute.

Step 6: Appeals issues a decision

Appeals reviews whether the collection action followed applicable law, procedure, and IRS policy.

The CAP decision is generally binding on the IRS and taxpayer for the collection action being reviewed.

Unlike a timely Collection Due Process determination, a CAP decision generally cannot be appealed to the United States Tax Court.

What information goes on Form 9423?

Form 9423 requests information identifying the taxpayer and the disputed collection action.

Information commonly requested includes:

• The taxpayer’s name
• Current address
• Telephone number
• Social Security number or employer identification number
• The name of the taxpayer’s representative, when applicable
• The representative’s telephone number
• The tax form involved
• The tax periods involved
• The type of collection action being appealed
• The date of the manager conference or request
• A detailed explanation of why the taxpayer disagrees
• The taxpayer’s proposed solution
• The taxpayer’s signature and date

The taxpayer should include every applicable tax period and clearly explain the requested resolution.

What issues can be raised in a CAP appeal?

The argument should focus on the specific collection action or collection decision.

Possible issues may include:

• The IRS did not follow required collection procedures
• The proposed collection action is more intrusive than necessary
• The collection action would create an immediate economic hardship
• The IRS failed to properly consider an installment agreement
• The IRS incorrectly determined that an installment agreement defaulted
• The taxpayer complied with the terms of an existing payment agreement
• The IRS used incorrect financial information
• A levy should be released
• Levied property should be returned
• A lien-related request was incorrectly denied
• A reasonable collection alternative is available

The taxpayer should provide facts, documents, and a realistic proposed solution rather than relying only on a general statement that the collection action is unfair.

Can the tax liability itself be disputed through CAP?

CAP generally focuses on the collection action rather than reconsidering the underlying amount of tax owed.

A dispute about the underlying liability may require a different procedure, depending on how the tax was assessed and whether the taxpayer previously had an opportunity to challenge it.

Other procedures might include:

• Audit reconsideration
• An amended return
• A penalty-abatement request
• A refund claim
• A Collection Due Process hearing when legally permitted
• An identity-theft correction process
• Innocent spouse relief

The correct procedure depends on the origin of the assessment and the taxpayer’s prior opportunities to dispute it.

What documents should be included?

The supporting documents depend on the collection issue being appealed.

Useful documents may include:

• The IRS notice or letter
• Account transcripts
• Copies of prior correspondence
• Proof of payments
• Installment-agreement records
• Bank statements
• Pay stubs
• Business income records
• Monthly expense documentation
• Medical records supporting a hardship claim
• Loan or mortgage information
• Property valuation documents
• Evidence showing ownership of levied property
• Documents supporting a lien discharge or subordination request

Documents should be organized and directly connected to the disputed collection action.

Can a representative submit Form 9423?

An authorized representative may assist with the collection appeal and communicate with the IRS.

The representative may need a valid IRS Form 2848, Power of Attorney and Declaration of Representative, covering the applicable tax matters and periods.

The taxpayer and representative should make sure the IRS has current contact information and that every applicable tax period is listed correctly.

Appealing an installment-agreement decision

CAP may be particularly important when the IRS rejects, modifies, or terminates an installment agreement.

Before submitting an appeal, review:

• Whether all required returns have been filed
• Whether all monthly payments were made
• Whether new tax debt was created
• Whether required estimated-tax payments were made
• Whether payroll tax deposits were made
• Whether the IRS used accurate income and expense figures
• Whether the proposed payment is financially realistic

The taxpayer should provide evidence showing why the agreement should be approved, reinstated, or left unchanged.

Appealing a levy or seizure

When a levy or seizure is involved, time may be especially important.

Bank levies, wage levies, and property seizures can affect a taxpayer’s immediate ability to pay necessary living or business expenses.

Relevant information may include:

• The amount taken or proposed to be taken
• The source of the funds
• Whether the funds are legally exempt
• Whether the property belongs to someone else
• Whether the levy creates economic hardship
• Whether another collection arrangement is available
• Whether the IRS followed the required procedures

A completed levy or seizure may be subject to different deadlines than a proposed action. The taxpayer should review the current IRS instructions immediately.

Common Form 9423 mistakes

• Waiting too long to request the manager conference
• Missing the deadline after the manager conference
• Sending the form to the wrong IRS office
• Failing to list every relevant tax period
• Failing to identify the specific collection action
• Providing only a vague explanation
• Not proposing a reasonable alternative
• Submitting no supporting documents
• Failing to sign and date the form
• Assuming CAP provides Tax Court rights
• Ignoring later calls or document requests from Appeals
• Creating new unpaid tax debt during the process

Simple steps to take right now

Do this now

• Find the complete IRS notice or collection letter.
• Identify the tax periods involved.
• Write down the collection action being proposed or taken.
• Review every deadline stated in the notice.
• Contact the assigned IRS collection employee.
• Request a conference with the collection manager when applicable.
• Write down the date and time of the manager-conference request.
• Prepare a clear explanation of why the collection action should be changed.
• Gather documents supporting your position.
• Keep copies of the completed form and every attachment.
• Preserve proof of mailing, faxing, or delivery.

Do not rely on a general assumption about the deadline. Use the instructions connected to the specific collection action and IRS notice.

You may have more than one resolution option

An appeal does not necessarily resolve the underlying tax debt by itself.

Depending on the taxpayer’s financial condition and account history, possible collection alternatives may include:

• A standard installment agreement
• A Partial Payment Installment Agreement
• Currently Not Collectible status
• An Offer in Compromise
• Penalty relief
• A levy release
• Return of levied property when legally permitted
• Lien withdrawal
• Lien subordination
• Discharge of property from a federal tax lien
• Another collection arrangement

The appropriate strategy depends on the collection notice, deadlines, balance, tax periods, filing compliance, income, expenses, assets, and prior IRS activity.

Related educational resources

• 
  What Is IRS Form 12153?
  
• 
  What Is an IRS Collection Due Process Notice?
  
• 
  What Is an IRS Tax Levy?
  
• 
  What Is an IRS Installment Agreement?
  
• 
  What Is IRS Form 2848?
  

Official IRS resources

View IRS Form 9423, Collection Appeal Request

Review IRS Publication 1660, Collection Appeal Rights

Review IRS instructions for preparing an appeal request

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Frequently asked questions

What is IRS Form 9423?

IRS Form 9423 is the Collection Appeal Request used to request review of certain IRS collection actions through the Collection Appeals Program.

What is the Collection Appeals Program?

The Collection Appeals Program is an IRS administrative appeal process for certain proposed or completed collection actions.

What collection actions can be appealed?

Depending on the circumstances, CAP may be available for certain liens, levies, seizures, installment-agreement decisions, and requests involving levied property.

Do I speak with an IRS manager before submitting Form 9423?

In many field-collection cases, the taxpayer generally first requests a conference with the collection employee’s manager. If the issue is not resolved, the taxpayer may then submit Form 9423 according to the applicable instructions.

How long do I have to submit Form 9423?

The deadline depends on the collection action and IRS procedure. Some deadlines are only a few business days, so the applicable notice and current instructions should be reviewed immediately.

Does Form 9423 automatically stop collection?

Not necessarily in every situation. The effect depends on the action involved, the timing of the appeal, and whether collection is considered at risk.

Can I appeal a CAP decision to Tax Court?

A CAP decision generally does not provide the same right to United States Tax Court review as a timely Collection Due Process determination.

Can Form 9423 eliminate my tax debt?

No. The form requests review of a collection action. The underlying tax balance must still be addressed unless it is separately changed or resolved.

Can I propose an installment agreement?

Yes. A taxpayer may propose a payment arrangement or another collection alternative, but approval depends on eligibility, compliance, financial information, and IRS requirements.

Where should Form 9423 be submitted?

The taxpayer should follow the specific instructions from the IRS collection employee, manager, notice, and current form instructions.

What is the first step?

Review the complete IRS notice, identify the collection action and deadline, and contact the assigned collection employee to discuss the issue.

Disclaimer: Educational information only. Not tax or legal advice.
Appeal rights, deadlines, collection protections, and available
resolution options depend on the specific notice, collection action,
tax periods, account history, and current law. No attorney-client
relationship is formed.