Navigating the Collection Appeals Program as a taxpayer

Auerbach Law Group, P.C. • December 20, 2024

Taxpayers who face specific IRS collection actions can challenge them through the Collection Appeals Program (CAP). This program provides a streamlined process to resolve disputes quickly and fairly. 


Understanding how CAP works can help taxpayers navigate the system and protect their rights.


Filing a CAP appeal

The first step in the CAP process is submitting Form 9423, Collection Appeals Request. You must file this form within 30 days of the collection action, such as a levy or lien. CAP appeals are unique because they allow taxpayers to contest actions without waiting for a notice of federal tax lien or levy to be issued. 


Unlike the Collection Due Process (CDP) hearing, CAP does not address the validity of the underlying tax debt. Instead, it focuses on the appropriateness of the IRS’s collection actions.


What actions qualify for CAP?

CAP applies to specific IRS collection activities. Taxpayers can appeal decisions related to levies or seizure of property and denial or termination of installment agreements.


Notices of federal tax liens.

New York taxpayers should be aware that state laws may influence the treatment of certain collection actions, such as property seizures. Familiarity with both federal and New York state guidelines ensures taxpayers are prepared to address their unique situations.


Resolving disputes efficiently

CAP appeals are generally resolved faster than CDP hearings. Once the Office of Appeals receives the request, they will review the case and make a determination. This expedited timeline can provide relief for taxpayers concerned about immediate enforcement actions.


Making informed decisions

The Collection Appeals Program offers an effective avenue to address disputes with the IRS. By understanding the CAP process and acting quickly, taxpayers can work toward resolution while minimizing financial and legal impacts. For those in New York, staying informed about state-specific considerations ensures a comprehensive approach to managing collection disputes.

A blue folder with
January 13, 2026
Learn what happens after an IRS civil tax audit in New York, possible outcomes, next steps, and how Auerbach Law Group, P.C. can help protect your rights. Call (212) 840-2180 today.
Hands with miniature house, pen, and documents at a desk; business meeting.
December 16, 2025
Why Estate Planning Matters in New York: Wills, Trusts, and Peace of Mind
Woman in blue blazer points pen at laptop, representing business disputes in New York.
November 18, 2025
Resolving Business Disputes in New York: Why Legal Strategy Matters
Calculator, tax forms, cash, and pen on a desk, suggesting IRS audit representation in NY.
October 21, 2025
How to Handle an IRS Audit: What You Should Know Before Responding
September 23, 2025
This is a subtitle for your new post
A bunch of papers are falling from the sky.
August 26, 2025
Tax Controversies in New York: Protecting Your Rights Against the IRS and State Authorities
A judge is holding a wooden gavel in front of a laptop computer.
July 29, 2025
What to Expect When Your Case Goes to Federal Tax Court in New York
A man and a woman are sitting at a table looking at a tablet.
June 3, 2025
What New York Entrepreneurs Need to Know About Business Formation
May 6, 2025
Estate and Trust Planning Solutions for Families and Business Owners in New York
Two men are shaking hands in an office.
April 8, 2025
Discover how to form an LLC in New York with ease. Follow our detailed guide on naming your LLC, filing paperwork, publishing notices, and meeting state requirements. Auerbach Law Group, P.C. provides experienced legal support to streamline the process.