Tax Relief AnswersIRS Form 9423: Collection Appeal Request Explained
The short answer
Form 9423, Collection Appeal Request, is the written request for the IRS Collection Appeals Program (CAP). It covers liens, levies, seizures, and installment agreements that were rejected, modified or terminated. The form's instructions say it goes to the IRS collection office that took the action, never directly to Appeals, and the deadlines are short: generally 3 business days after a conference with a collection manager for a lien, levy or seizure, and 30 calendar days for an installment agreement decision. The current revision is February 2020 (checked November 2026), with no Spanish version listed.
Form 9423 at a glance
| Item | What irs.gov shows |
|---|---|
| Purpose | Appeal certain IRS collection actions under the Collection Appeals Program |
| Current revision | February 2020; no Spanish version listed |
| Who can file | A taxpayer, or a third party whose property is subject to the collection action |
| How it is sent | To the collection office or revenue officer involved, not to Appeals |
| Online option | None shown |
| Fee | None listed |
What it can appeal
The instructions list:
- a levy or seizure that has been or will be taken;
- a notice of federal tax lien that has been or will be filed, including against an alter ego or nominee;
- denials of lien certificates such as subordination, withdrawal, discharge or non-attachment;
- installment agreements that were rejected, proposed for modification or modified, or proposed for termination or terminated;
- denials of requests to return levied property.
Deadlines from the form and Publication 1660
| Situation | What to do and when |
|---|---|
| Lien, levy or seizure after contact with a revenue officer | Ask for a conference with the collection manager first. Tell the office within 2 business days after it that you will appeal; Form 9423 must be received or postmarked within 3 business days of the conference |
| Seizure | Appeal to the collection manager within 10 business days after the notice of seizure |
| Manager does not contact you within 2 business days | Submit Form 9423 within 4 business days of your conference request |
| Installment agreement rejected, modified or terminated | Give Form 9423 to the office or revenue officer that acted, within 30 calendar days |
IRS Publication 1660 adds that if your only contact has been a notice or a phone call, you can appeal by phone through a manager without a written request, and that an installment agreement appeal needs to be in writing only if a revenue officer sent the letter.
What happens next
The instructions say the IRS normally stops the collection action you appeal until the appeal is settled, unless collection is at risk. Appeals' decision is binding on you and the IRS, and you cannot take a CAP decision to court. You may represent yourself or use an attorney, CPA or enrolled agent; for a representative to appear without you, a Form 2848 is required.
CAP or a CDP hearing?
CAP covers more kinds of actions, including installment agreement decisions, but it has no court review. A Form 12153 Collection Due Process hearing is available after a CDP notice, has a 30-day window and allows Tax Court review. Our appeals guide covers both.
Steps
- Ask for a conference with the collection manager, unless your appeal is about an installment agreement.
- Download the current Form 9423 from irs.gov.
- Check the action you disagree with, explain why and propose a solution, as the form asks.
- Give it to the collection office or revenue officer involved within the deadline.
- Keep a copy and proof of the date.
Common mistakes
- Mailing Form 9423 to Appeals. The instructions say never to send it there directly.
- Missing the 3-business-day window after a manager conference, after which collection may resume.
- Leaving out a proposed solution. The form asks you to explain how you would resolve the problem.
Related pages: CP523 notice (intent to terminate a payment plan), bank levy, federal tax lien and Form 14135 for lien discharge.
FAQ
What is IRS Form 9423 used for?
Form 9423 is the written request to appeal certain collection actions, such as liens, levies, seizures and installment agreement decisions, under the Collection Appeals Program. The current revision is February 2020, checked November 2026.
Where do I send Form 9423?
To the IRS collection office or revenue officer that took the action. The instructions say never to send it directly to Appeals.
What is the deadline for Form 9423?
For a lien, levy or seizure, generally within 3 business days of your conference with the collection manager. For an installment agreement decision, within 30 calendar days.
Can I go to court after a Collection Appeals Program decision?
No. The Form 9423 instructions say Appeals' CAP decision is binding and cannot be reviewed by a court, although other remedies may exist in some cases.