Collection Appeals Program (CAP)
An appeal route covering liens, levies, seizures and installment agreement decisions. Several different clocks apply depending on what you are appealing — check which one is yours. An Appeals decision after CAP is binding and cannot itself be taken to court, though the IRS says other review routes may remain for the underlying issue.
Full Definition
The Collection Appeals Program is the route for disputing a collection action itself. The IRS lists what can be appealed under it: a levy or seizure that has been or will be taken; a Notice of Federal Tax Lien that has been or will be filed; the filing of a notice of lien against an alter-ego or nominee's property; denials of requests to issue lien certificates such as subordination, withdrawal, discharge or non-attachment; installment agreements that are rejected, proposed for modification or modified, or proposed for termination or terminated; and two categories of disallowed claims for return of levied property under IRC 6343.
The most important thing to understand about CAP is what you give up. The IRS states that once Appeals makes a decision it is binding on both you and the IRS, and that you cannot obtain judicial review of that decision following a CAP. It adds that there may still be other opportunities to obtain administrative or judicial review of the issue raised in the CAP hearing — the example it gives is a third party contesting a wrongful levy in district court. So the decision itself is final; the underlying issue may not be. A Collection Due Process hearing under section 6330 works differently and preserves a route to Tax Court. If you hold a notice that carries CDP rights, that difference is worth understanding before choosing.
The IRS states that when you appeal, it will normally stop the collection action you disagree with until the appeal is settled, unless it has reason to believe collection or the amount owed is at risk. You may represent yourself or be represented by an attorney, a certified public accountant, or a person enrolled to practice before the IRS; a representative appearing without you needs a completed Form 2848.
What to do next
Before choosing this route, check whether your notice carries Collection Due Process rights. A CDP hearing preserves a route to Tax Court; an Appeals decision after CAP is binding and not itself reviewable, though the IRS says other routes may remain for the underlying issue.
What this page does not say
- The instructions we read are Revision 2-2020. That is old for an IRS procedural document, and procedure is exactly what this entry describes — confirm the current revision on irs.gov before acting on the sequence or the deadlines.
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 2026-08-20 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.