Property Seizure
A levy carried out against physical property. Appealing after one runs on a ten-business-day clock from the Notice of Seizure.
Full Definition
Seizure is a levy carried out against property in the physical sense — the IRS taking possession of a vehicle, real estate or other assets rather than intercepting money.
The IRS treats seizure as its own appealable collection action. The instructions to Form 9423 list "levy or seizure action that has been or will be taken" among the matters that can go to the Collection Appeals Program.
The deadline after a seizure is short, published, and different from every other CAP deadline: "If you request an appeal after IRS makes a seizure, you must 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."
Ten BUSINESS days, from when the notice was provided or left — not from when it was read. That is the only interval on the form measured from a document being left somewhere.
What to do next
If a Notice of Seizure has been provided or left, count ten business days from that moment and appeal to the Collection manager within it. That is the IRS's own instruction and it is the shortest clock in the Collection Appeals Program.
Sources
- Form 9423, Collection Appeal Request (Rev. 2-2020) — instructions — Internal Revenue Service, retrieved 2026-08-20
- Publication 594, The IRS Collection Process — 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.