The Collection Appeal Program (CAP) is an IRS program that allows taxpayers to appeal certain collection actions, including levies, liens, and the termination of Installment Agreements, either before or after the actions are enforced. CAP provides an opportunity for taxpayers to dispute or negotiate with the IRS before a levy or lien is executed, giving them a chance to resolve the issue without facing immediate financial hardship.
Key actions that can be appealed under CAP include:
- Levy actions: Both before and after a levy has been issued.
- Lien actions: Including the filing of a lien or a refusal to withdraw it.
- Termination of an Installment Agreement: When the IRS cancels an existing payment plan.
To initiate a CAP appeal, taxpayers must file Form 9423 (Collection Appeal Request) with the IRS. The IRS will then review the appeal and decide whether the collection action was appropriate. The CAP appeal process is faster than other types of appeals, such as a Collection Due Process (CDP) hearing, making it a valuable tool for taxpayers facing immediate enforcement actions.