Internal Revenue Service (IRS) Edition Rev. February 2020 2 pages

Form 9423 — Collection Appeal Request

The IRS form for appealing a lien, levy, seizure or installment agreement decision under the Collection Appeals Program (CAP).

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Form 9423 · Collection Appeal Request
The official Internal Revenue Service (IRS) form, edition Rev. February 2020 — blank
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Form 9423 (2020) Collection Appeal Request — page 1 of 2
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Form 9423 (2020) Collection Appeal Request — page 2 of 2
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What is Form 9423?

Form 9423, Collection Appeal Request, asks the IRS Independent Office of Appeals to review a collection action you disagree with under the Collection Appeals Program (CAP). It covers federal tax liens, levies or proposed levies, seizures, and installment agreements that were rejected, modified or terminated (or proposed for modification or termination). A third party whose property is subject to a collection action can use it too. The current edition is Rev. February 2020.

The deadlines are short and depend on the action. For a lien, levy or seizure, you first ask for a conference with the IRS employee's manager; if that doesn't settle it, you tell the Collection office within two business days that you'll appeal, and the form must be received or postmarked within three business days of the conference, or collection may resume. For an installment agreement decision, you give the form to the office or revenue officer who took the action within 30 calendar days. The form goes to that Collection office, never directly to Appeals.

FileIt walks you through each line, checks that your explanation fits the box, and prints everything into the IRS's official PDF, saved in your vault. You (or your authorized representative) sign it and deliver it yourself; FileIt never sends anything to the IRS.

Who fills it
A taxpayer, or a third party whose property is subject to an IRS collection action, or their authorized representative.
Given to
The IRS Collection office (or revenue officer) involved in the action, not Appeals directly.
Deadline
Lien, levy or seizure: within 3 business days of the manager conference. Installment agreement: within 30 calendar days.
Signatures
The taxpayer or the authorized representative (one of them), under penalties of perjury.
Edition
Rev. February 2020
Agency
Internal Revenue Service (IRS), Department of the Treasury

Who needs to fill out Form 9423?

  • Taxpayers facing a levy on wages or a bank account, or a proposed levy, they believe is wrong.
  • Taxpayers whose property has been or will be seized, or against whom a Notice of Federal Tax Lien has been or will be filed.
  • Taxpayers whose installment agreement was rejected, modified or terminated, or proposed for modification or termination.
  • Third parties whose property is subject to a lien, levy or seizure for someone else's tax debt, or whose request to issue lien certificates was denied.

When to use Form 9423

  • After a conference with the Collection manager hasn't resolved a lien, levy or seizure dispute, within three business days of that conference.
  • If you asked for a manager's conference and weren't contacted within two business days: the form should then be received or postmarked within four business days of your request.
  • Within 30 calendar days of an installment agreement being rejected, modified or terminated. A manager conference isn't required, though the IRS strongly recommends one.
  • After a seizure, the appeal to the Collection manager must be within 10 business days after the Notice of Seizure is given to you or left at your home or business.

What you need before you start

  • The taxpayer's name, SSN or EIN, phone numbers and address.
  • Your representative's name and phone, and a copy of Form 2848 if they will appear without you.
  • The type of tax (tax form), the tax periods being appealed and the tax due.
  • Which collection actions you're appealing, and the date of your manager conference (or of your request for one).
  • Your explanation and proposed solution, and copies of any documents supporting your position.

What’s on Form 9423

The 2020 edition has 2 pages. FileIt asks for it in 4 parts, and it is signed by Taxpayer or representative:

  1. Lines 1 to 10: Taxpayer and representativeTaxpayer or representative
  2. Lines 11 to 14: The tax and the collection actionTaxpayer or representative
  3. Line 15: ExplanationTaxpayer or representative
  4. Line 16: Who signsTaxpayer or representative

How to fill out Form 9423, step by step

1 Lines 1 to 10: Who's appealing

Enter the taxpayer's name, SSN or EIN, business and home phone numbers, street address, city, state and ZIP code. If you have a representative, enter their name and phone and attach a copy of Form 2848, Power of Attorney.

2 Lines 11 to 13: The tax

Enter the type of tax (the tax form), the tax periods you're appealing and the tax due.

3 Line 14: The actions

Check every collection action you're appealing: federal tax lien, levy or proposed levy, seizure, or rejection, termination or modification of an installment agreement.

4 Line 15: Your explanation

Explain why you disagree with each action and how you would resolve your tax problem, for example a payment you can afford. If you weren't contacted after asking for a manager's conference, give the date of your request and say so. Attach additional pages and copies of supporting documents if needed. Appeals generally asks Collection to review any new information and shares their comments with you.

5 Lines 16 and 17: Sign

Check whether the taxpayer or the authorized representative is signing (only one), then sign and date. The declaration is made under penalties of perjury.

Common mistakes to avoid

  • Missing the deadline. For liens, levies and seizures it's a matter of business days after the manager conference.
  • Sending the form directly to Appeals. It must go to the Collection office that took the action.
  • Skipping the manager conference for a lien, levy or seizure appeal: it comes first.
  • Explaining the disagreement but not proposing a solution. The form asks for both.
  • Checking both signature boxes. Only the taxpayer or the representative signs.

After you fill it out

Sign and date it, attach any supporting documents (and Form 2848 for a representative), and deliver it to the Collection office or revenue officer involved, within the deadline. FileIt keeps a copy in your vault.

Normally the IRS stops the collection action you're appealing until the appeal is settled, unless it believes collection or the amount owed is at risk.

Appeals' decision is binding on you and the IRS, and you can't get judicial review of it after a CAP, although other review routes may exist (for example a wrongful levy claim). Publications 594 and 1660 explain the process.

Fill out Form 9423 online with FileIt

  1. Pick the person. Choose someone from People and FileIt fills in their name, date of birth, address and other details it already knows.
  2. Answer plain-language questions. One part of the form at a time, with the official help text beside each question — 21 fields in all. Your answers save as you go.
  3. Check the live preview. Watch your answers land on the real Internal Revenue Service (IRS) form, and let FileIt do any worksheet arithmetic.
  4. Generate the official PDF. FileIt prints your answers into the agency’s own PDF and files it in that person’s folder in your vault. Sign it, or send it for e-signature.

FileIt fills the form — it never files or submits anything for you. Deliver the finished form to whoever asked for it, the way the form’s instructions say.

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Form 9423: frequently asked questions

What can I appeal with Form 9423?

Levies and seizures, Notices of Federal Tax Lien, liens filed against an alter ego's or nominee's property, denied lien certificates, rejected, modified or terminated installment agreements, and certain disallowed requests to return levied property.

Where do I send Form 9423?

To the Collection office involved in the action, or the office or revenue officer who took the action on your installment agreement. Never forward it directly to Appeals.

How long do I have to file Form 9423?

For a lien, levy or seizure, it must be received or postmarked within three business days of your conference with the Collection manager. For an installment agreement decision, within 30 calendar days.

Will the IRS stop collecting while I appeal?

Normally the IRS stops the collection actions you disagree with until the appeal is settled, unless it has reason to believe collection or the amount owed is at risk.

Can someone represent me?

Yes: an attorney, certified public accountant or a person enrolled to practice before the IRS. To have them appear without you, provide a completed Form 2848.

Can I go to court if I lose the appeal?

Not to review the CAP decision itself: it's binding and there's no judicial review of it. Other administrative or judicial routes may be available for some issues, such as a third party's wrongful levy claim in district court.

Official sources

FileIt is not affiliated with or endorsed by Internal Revenue Service (IRS) or any government. This page explains the form in general terms and is not legal, tax or immigration advice. Always read the official instructions, and check that you are using the edition the recipient accepts. Page last reviewed 2026-10-01.

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