You may appeal many IRS collection actions to the IRS Office of Appeals (Appeals). The two main procedures are Collection Due Process (CDP) and Collection Appeals Program (CAP).

Collection Appeals Program (CAP) is available for the following actions:

  • Before or after the IRS files a Notice of Federal Tax Lien.
  • Before or after the IRS levies or seizes your property.
  • Termination of an installment agreement.
  • Rejection of an installment agreement.

However, you can’t go to court if you disagree with the CAP decision.

Collection Due Process (CDP) – By law, you have the right to a CDP hearing by Appeals

  • The first time a Notice of Federal Tax Lien is filed for a tax and period.
  • Before the first levy on your property for a tax and period.
  • After levy on your state refund.
  • After levy when collection is in jeopardy.