Collection Appeals

There are different options that a taxpayer may have in appealing IRS collection activity.

Collection Appeals Program

The Collection Appeals Program, or CAP, is a program that was implemented by the IRS in 1996. It offers a taxpayer the right to appeal particular IRS collection actions, including levies, seizures, and liens. When you file an appeal of this kind, the Appeals Officer assigned to rule upon the matter is expected to come to a decision within 5 business days.

Collection Due Process Appeal

Before the IRS can levy assets or income, or record a lien, it must first provide a notice of its intent and the right of the taxpayer to appeal this collection action. A collection due process appeal hearing offers a taxpayer the opportunity to work with the IRS Appeals Office to come to a less aggressive resolution.

Collection Due Process Equivalent Hearing

Should a taxpayer fail to request a collection due process hearing within the required 30-day time period, there may be an option to request what is called an equivalent hearing. This hearing is similar to a standard collection due process hearing, with three main exceptions: collection action does not have to cease while the equivalent hearing is pending, the statute of limitations is not suspended, and there is no judicial review.

If you are facing collection activity, call us to learn more about your right to appeal IRS collection and how we can help.