IRS Form 9423 “Collection Appeal Request” Explained

IRS Form 9423, Collection Appeal Request, is used to request review by the IRS Independent Office of Appeals under the Collection Appeals Program (CAP). CAP is a fast appeal process for many IRS collection actions, but its decisions are final. There’s no Tax Court review.

What You Can Appeal Through CAP

• Before or after the IRS files a Notice of Federal Tax Lien
• Before or after a levy or seizure of your property
• The rejection, proposed termination or modification of an installment agreement
• The denial of a request to return levied property
• Denials of lien withdrawal, subordination or discharge requests

How the Process Works

For lien, levy and seizure actions handled by a revenue officer:

1. Ask for a conference with the revenue officer’s manager.
2. If you can’t resolve it, submit Form 9423 to the collection office, generally within 2 business days after the manager conference.
3. Appeals typically decides within a few business days.

For a rejected or terminated installment agreement, the time to request a CAP appeal is generally 30 days from the IRS notice. Follow the specific instructions in IRS Publication 1660 and on any notice you receive.

CAP vs. Collection Due Process (CDP)

• CAP (Form 9423): available for more types of actions and at more points in the process, and much faster. Decisions are binding with no Tax Court review, and you can’t dispute the underlying tax.
• CDP (Form 12153): available only after certain lien and levy notices, with a strict 30-day deadline. It’s slower, but levies are suspended, you can raise more issues, and you can go to Tax Court.

If you received a CDP notice, consider whether CDP gives you better protection before choosing CAP.

Completing Form 9423

• Identify the collection action and the tax periods.
• Explain why you disagree and what you propose instead, such as an installment agreement, release of a levy, or subordination.
• Attach supporting documents, often including a current Form 433-A or 433-B.

Get Help From Diehl CPA

IRS collection and appeal procedures have strict deadlines, and what you submit becomes part of the record. Diehl CPA, led by Mark Diehl, CPA, CFE, represents taxpayers before the IRS and can prepare the forms, gather the documentation, and deal with the IRS for you. Learn about our tax relief services or contact us to talk through your situation.

This article is general information, not tax or legal advice for your specific situation. Updated October 2026.