If you disagree with the IRS employee’s decision concerning lien or levy, or proposed lien or levy actions, you can call the IRS at the telephone number on your notice or the number you spoke to the employee at. Be prepared to explain which action(s) you disagree with, why you disagree, and a proposed solution. If you cannot reach an agreement, advise the employee you would like to appeal. The employee must refer you to their manager. If the manager is not available to speak immediately, they should return your call within 24 hours.
If you request an appeal after IRS makes a seizure, you must appeal to the Collection manager within 10 business days after the Notice of Seizure is provided to you or left at your home or business with the manager.
If the manager sustains the employee’s decision, you can submit a request for Appeals consideration verbally, in writing, or via Form 9423 to the IRS employee within three business days of meeting with the manager. If you have been in contact with a Revenue Officer use Form 9423 for CAP appeal requests.
If possible, advise the employee or manager that you will be filing a CAP appeal within two (2) days of the manager’s conference. Otherwise collection action may resume.
If you request a conference and are not contacted by a manager or his/her designee within two (2) business days of making the request, you can contact Collection again or submit Form 9423. If you submit Form 9423, note the date of your request for a conference in Block 15 and indicate that you were not contacted by a manager. The Form 9423 should be received or postmarked within four (4) business days of your request for a conference as collection action may resume.
If you disagree with the IRS employee’s decision concerning rejection or termination of an installment agreement, you will have 30 days from the date of the notice to appeal. You can contact the employee’s manager to request a conference, but a manager conference is NOT required to be attempted for appeals involving installment agreements; however, it is encouraged one be held whenever possible. If the manager sustains the employee’s decision, you can submit a request for Appeals consideration in writing, via Form 9423. Your written request must be postmarked within 30 days from the date of the notice to be considered.
If you disagree with the proposed modification or modification of your installment agreement, please follow the directions under the section of your notice entitled, “How do you appeal the termination of an installment agreement?”
You may represent yourself or you may be represented by an attorney, certified public accountant, or a person enrolled to practice before the IRS. Also, you may be represented by a member of your immediate family, or in the case of a business, by regular full-time employees, general partners, or bona fide officers. If you want your representative to contact the IRS or appear without you and to receive and inspect confidential material, you must file a properly completed Form 2848 (no earlier than 10/2011 revision), Power of Attorney and Declaration of Representative.
Under CAP, Appeals does not consider alternatives to the issue under appeal, nor will it consider the existence or amount of your tax liability, but solely determines the appropriateness of the issue under appeal. Appeals’ administrative decisions are final and there is no right to judicial review in court if you disagree with the decision. If your issue is not resolved through CAP you can explore “I Need Help Resolving My Balance Due” on the TAS website.
Never forward your request for an Appeals conference directly to Appeals. It must be submitted to the office which took the action on your installment agreement.
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