Form 9423 is the IRS Collection Appeal Request — how you formally challenge a collection action like a lien, levy, or seizure under the Collection Appeals Program (CAP). It's free, but it's time-sensitive: you generally have a short window after your conference with the collection manager. What decides the outcome is stating exactly what you disagree with and the solution you propose.
What Form 9423 Is
Form 9423, "Collection Appeal Request," lets you ask the IRS Office of Appeals to review certain collection actions through the Collection Appeals Program. It applies to things like a filed or proposed federal tax lien, a levy or proposed levy, a seizure of property, or the rejection, modification, or termination of an installment agreement. Appeals is independent of the collection function, so it's a genuine second look — not the same officer reconsidering.
The Deadline Is the Most Important Part
CAP is fast and strict. In most situations you first try to resolve the issue with the collection employee and, if that fails, request a conference with their manager — then you have a limited number of days to file Form 9423 to move it to Appeals. Miss that window and you may lose the CAP route for that action. Because the exact timing depends on the specific action, confirm your deadline on irs.gov or in the notice you received, and file promptly rather than at the edge.
How to Fill Form 9423
- Taxpayer information. Your name, address, SSN or EIN, and a phone number.
- Tax details. The type of tax and the periods involved, plus the collection action you're appealing (lien, levy, seizure, installment-agreement decision).
- Your explanation. The heart of the form: state clearly why you disagree with the action and propose a specific alternative or solution. Vague disagreement without a proposed resolution is the most common reason a CAP appeal goes nowhere.
- Sign and date. You sign, or an authorized representative does.
Can someone represent me on a Form 9423 appeal?
Yes. A tax professional can handle the appeal for you, but they need authorization on file — that's what Form 2848 Power of Attorney provides. With a 2848 naming them for the tax periods at issue, an attorney, CPA, or enrolled agent can file and argue the 9423 on your behalf and receive the IRS's correspondence about it.
Is there a fee to file Form 9423?
No. Filing a Collection Appeal Request costs nothing. It's a taxpayer right built into the collection process — the only real cost is the tight deadline, so the priority is filing on time with a clear, specific explanation of the resolution you want.