Collection Appeals Program Decision
A CAP decision binds both sides and cannot be taken to court. That is the trade against how fast it is.
Full Definition
A decision from the Collection Appeals Program is final in a way a Collection Due Process determination is not.
The instructions to Form 9423 state it plainly: "Once Appeals makes a decision regarding your case, that decision is binding on both you and the IRS. You cannot obtain a judicial review of Appeals' decision following a CAP."
That is the trade. CAP is quicker and reaches more actions than CDP — liens, levies, seizures, alter-ego and nominee lien notices, denials of lien certificates, and installment agreement decisions — and it ends where it ends.
The instructions do name routes that survive: "there may be other opportunities to obtain administrative or judicial review of the issue raised in the CAP hearing. For example, a third party may contest a wrongful levy by filing an action in district court."
And one thing that voids it: "Providing false information, failing to provide all pertinent information or fraud will void Appeals' decision."
What happens meanwhile: "Normally, we will stop the collection action(s) you disagree with until your appeal is settled, unless we have reason to believe that collection or the amount owed is at risk." Note the hedge — normally, and unless.
What to do next
If both routes are open on the same facts, the difference to weigh is what happens at the end: a CDP determination can be petitioned to the Tax Court, a CAP decision cannot be reviewed at all.
Sources
- Form 9423, Collection Appeal Request (Rev. 2-2020) — instructions — Internal Revenue Service, retrieved 2026-08-20
- Publication 1660, Collection Appeal Rights — Internal Revenue Service, retrieved 2026-08-18
Last reviewed 2026-08-21 by Tax Resolution Clarity editorial.
Sourced to primary IRS materials and editorially reviewed. Not reviewed by a tax professional. Not tax advice.
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Where to go next
The IRS publishes the rules this page describes. Your own notice governs your dates.