Form 9423 is the Collection Appeal Request, the form for asking the IRS Independent Office of Appeals to review a lien, a levy or seizure, or a rejected, modified or terminated installment agreement under the Collection Appeals Program (CAP). For liens, levies and seizures you first ask for a conference with the Collection manager, then the form must be received or postmarked within 3 business days of that conference. For an installment agreement you have 30 calendar days.
Everything below comes from IRS Form 9423 (Rev. 2-2020) and its instructions, and Publication 1660, Collection Appeal Rights, as of October 2026.
What you can appeal with Form 9423
A taxpayer, or a third party whose property is subject to the collection action, can appeal:
- a levy or seizure that has been or will be taken
- a Notice of Federal Tax Lien that has been or will be filed
- a notice of lien filed against an alter-ego's or nominee's property
- a refused request for a lien certificate, such as a subordination, withdrawal, discharge or non-attachment
- an installment agreement that was rejected, modified or terminated, or is proposed for modification or termination
- a refused request to return levied property under IRC 6343(d), or a refused owner's claim under IRC 6343(b)
The tight timeline for liens, levies and seizures
- Ask for a conference with the IRS employee's manager.
- If the conference doesn't settle it, tell the Collection office within 2 business days that you plan to file Form 9423.
- Make sure Form 9423 is received or postmarked within 3 business days of the conference, or collection may resume.
- If no manager contacts you within 2 business days of asking, you can submit Form 9423 anyway; note the date of your request in Block 15 and send it within 4 business days of that request.
- After a seizure, appeal to the Collection manager within 10 business days after the Notice of Seizure is given to you.
Send the form to the Collection office handling the lien, levy or seizure, not to Appeals.
Those business-day limits are the whole game. If the form arrives a day late, collection action may resume while you try again, so post it with proof of the mailing date or hand it to the office. Keep a copy of the form and every document you attach, because Appeals usually asks Collection for its view and then gives you the chance to respond.
Appealing an installment agreement decision
Here no manager conference is required, though the IRS strongly recommends one. Give Form 9423 to the office or revenue officer that acted on your installment agreement within 30 calendar days. Publication 1660 adds that if you appeal within that window, the IRS can't levy until the appeal is completed, unless it believes collection of the tax is in jeopardy. If you're asking for a new plan rather than appealing one, that's Form 9465.
Representatives and the final decision
You can represent yourself at the Appeals conference, or be represented by an attorney, a certified public accountant or a person enrolled to practice before the IRS. If you want your representative to attend without you, a completed Form 2848 is required. Once Appeals decides, the decision binds both you and the IRS, and providing false information, leaving out pertinent information or fraud voids it.
That doesn't close every door. The instructions point out that other reviews may still exist for the underlying issue; for example, a third party can contest a wrongful levy by filing in district court, as Publication 4528 explains. Pub. 594, The IRS Collection Process, covers the wider collection steps.
CAP or a Collection Due Process hearing?
This is the choice people miss. CAP is fast and covers more actions, but its decision is final. A Collection Due Process (CDP) hearing, requested on Form 12153 after a CDP notice, is slower but can be taken to the US Tax Court.
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| Collection Appeals Program (Form 9423) | Collection Due Process (Form 12153) | |
|---|---|---|
| Covers | Liens, levies, seizures, installment agreements, lien certificates, returned property | Liens and levies named in a CDP notice |
| Deadline | Days after the manager conference, or 30 days for installment agreements | Generally 30 days from the CDP notice |
| Court review | None: the Appeals decision binds you and the IRS | You can petition the US Tax Court |
| Collection while you wait | Normally stopped, unless collection is at risk | Levy generally stopped and the 10-year collection period suspended |
Filling in the form
- Blocks 1 to 13: your details, the type of tax, the periods and the amount due. If you have a representative, attach Form 2848.
- Block 14: tick each collection action you're appealing.
- Block 15: explain why you disagree and how you'd resolve the problem, with any documents that back you up.
- Blocks 16 and 17: sign and date. The IRS-use blocks are left for the revenue officer and manager.
Appeals usually asks Collection to review any new information and lets you respond to its comments. If the IRS action is causing economic harm, the Taxpayer Advocate Service is on 877-777-4778.
The verdict
Use Form 9423 when speed matters and the problem is the collection step itself, such as a levy that would hurt your business or a plan that was cut off. Bring a workable solution in Block 15, often a payment plan backed by a financial statement like Form 433-F. If you've received a CDP notice and might want a judge to look at it, request the CDP hearing instead, because CAP closes that door.
Frequently asked questions
What is Form 9423?
It's the Collection Appeal Request, used to appeal liens, levies, seizures and installment agreement decisions under the IRS Collection Appeals Program.
What is the deadline for Form 9423?
For a lien, levy or seizure, it must be received or postmarked within 3 business days of the conference with the Collection manager. For an installment agreement, within 30 calendar days.
Where do I send Form 9423?
To the Collection office or revenue officer that took the action. Never send it straight to Appeals.
Can I go to court after a CAP decision?
No. The Appeals decision under CAP is binding on you and the IRS and can't be taken to judicial review.
Does Form 9423 stop IRS collection?
Normally the IRS stops the action you're appealing until the appeal is settled, unless collection or the amount owed is at risk.
