
What IRS Form 9423 Is For
When the Internal Revenue Service takes action to collect unpaid taxes, taxpayers have the right to request a review through the IRS Form 9423 Collection Appeal Request. This form is part of the Collection Appeals Program (CAP), which provides an opportunity for taxpayers to dispute liens, levies, seizures, or rejected installment agreements. It provides a structured way for individuals and businesses to dispute federal collection actions that may have been issued in error or without proper review.
The Independent Office of Appeals conducts the review to ensure fair and lawful treatment. Unlike a court proceeding, this process allows for faster resolution through administrative review. The goal is to help taxpayers protect their assets while addressing issues directly within the IRS framework.
When You’d Use IRS Form 9423
Taxpayers can file IRS Form 9423 when they disagree with a collection action or decision regarding their tax debt. The form applies when the Internal Revenue Service issues liens, levies, or seizures that affect income, personal assets, or business property. It also covers cases where the IRS rejects a proposed monthly payment plan or modifies a partial payment installment agreement.
Taxpayers can use IRS Form 9423 to appeal the following actions:
- Taxpayers have the right to appeal federal tax liens that affect real property, personal assets, or life insurance policies.
- Appeals may also be filed for levies placed on wages, bank accounts, or business assets.
- Rejected or terminated installment agreements tied to specific tax periods may qualify for appeal.
- The IRS may be challenged on actions involving lump-sum payments or assessments on unpaid tax returns.
- Collection measures that threaten necessary living expenses or essential income can also be appealed.
Filing this form gives taxpayers a fair opportunity to present detailed information about their tax situation and seek a resolution.
Key Rules or Details for 2025
Taxpayers must follow specific procedures when submitting a Collection Appeal Request for a valid review. The Internal Revenue Service requires a completed form that identifies the tax periods, collection actions, and supporting evidence. Each taxpayer’s request must meet the filing deadlines stated in the official IRS notice.
Manager Conference Requirement
The Internal Revenue Service requires taxpayers to meet with a collection manager before filing the appeal form. This discussion provides an opportunity to address the proposed levy, lien, or other tax collection action. If the disagreement continues, the taxpayer may proceed through the collection appeals process.
Scope of Appeals Review
After the required manager conference, the Independent Office of Appeals determines whether the agency followed correct procedures. The office does not reconsider the underlying tax liability or overturn previous findings. Legal support from a tax attorney may be beneficial.
Step-by-Step (High Level)
Taxpayers must complete several key steps to file IRS Form 9423 properly. Each stage helps ensure that the Internal Revenue Service reviews the case accurately and processes it without delay. Careful preparation increases the chance of a fair outcome during the appeal process.
- Step 1: The individual should contact the IRS employee listed on the notice to discuss the issue directly.
- Step 2: If the concern remains unresolved, a meeting with the collection manager should be requested.
- Step 3: The filer must complete the form with accurate tax periods, clear explanations, and relevant supporting documentation.
- Step 4: The completed and signed form should then be mailed to the appropriate IRS office before the filing deadline.
- Step 5: The applicant should wait for the appeals conference and prepare to present their position to an Appeals Officer or a qualified tax professional.
Common Mistakes and How to Avoid Them
Many taxpayers make mistakes when completing the Collection Appeal Request Form. Recognizing and preventing these errors helps ensure the Internal Revenue Service accepts the appeal. Careful preparation improves both accuracy and timeliness in the collection process.
- Missed Filing Deadlines: Mark deadlines immediately after receiving the IRS notice. Mail the form within the required timeframe using certified mail. Keeping documentation verifies that the appeal was submitted on time.
- Skipping the Manager Conference: Always schedule and attend the required conference with the collection manager. Use the meeting to explain your position clearly. Record the outcome for inclusion with your appeal.
- Incomplete Information: Review all sections of the form for accuracy before submission. Include complete tax period details and explanations. Attach supporting documents to strengthen your appeal.
Effective preparation ensures the appeal process proceeds smoothly and efficiently.
What Happens After You File
After a taxpayer submits IRS Form 9423, the Internal Revenue Service forwards it to the Independent Office of Appeals for review. The assigned Appeals Officer evaluates the case and confirms that the submission meets the program’s filing requirements. The IRS revenue officer involved in the initial collection provides documents and explanations to support the prior action.
The appeals review examines whether the agency followed proper procedures during the collection process. The review does not reconsider the underlying tax liability or address unrelated issues. If the officer determines that collection actions were inappropriate, the agency may suspend or modify them.
When the review ends, the taxpayer receives a written appeals decision describing the outcome. The IRS files any necessary adjustments to close the case. Taxpayers who need further help may contact the Taxpayer Advocate Service for assistance.
FAQs
What is the IRS Collection Appeals Program?
The IRS Collection Appeals Program, or CAP, allows taxpayers to challenge IRS collection actions such as levies, seizures, or federal tax lien filing. It offers a faster resolution process compared to a Collection Due Process hearing. CAP helps taxpayers resolve disputes without going to Tax Court.
When should a taxpayer request a CAP hearing?
A taxpayer should request a CAP hearing upon receiving a notice of federal tax lien or a proposed levy. The request must be filed promptly with the IRS collection office managing the case. Acting quickly helps prevent further enforcement while the appeal is reviewed.
How does a CAP appeal differ from a Collection Due Process hearing?
A CAP appeal focuses on whether the Internal Revenue Service followed correct procedures during the collection process. A Collection Due Process hearing provides broader rights, including the option for judicial review in Tax Court. CAP does not allow an equivalent hearing once the appeal period closes.
What happens during a CAP hearing?
During a CAP hearing, an appeals officer reviews whether the IRS collection actions complied with the tax code. The officer may request financial statements, documentation, or evidence regarding levied property. If necessary, the IRS may return levied property or release a lien after review.
What if the taxpayer disagrees with the final decision?
Once the IRS appeal decision is issued, it becomes binding on both the taxpayer and the agency. CAP decisions cannot be appealed further through administrative or judicial review. A certified public accountant or tax attorney can help explain the outcome and next steps.


