IRS Collection Appeals

When You Can Appeal IRS Collection Actions

If the IRS has rejected your installment agreement request, is threatening to levy your bank accounts, or is threatening to garnish your wages, you may have the right to file collection appeals — either a Collection Due Process Appeal or a Collection Action Program appeal.

These appeals give taxpayers a meaningful opportunity to challenge IRS collection decisions before an impartial IRS Appeals Officer. In many cases, a successful collection appeal can stop a levy or garnishment entirely or replace it with a more manageable resolution.

Collection Due Process (CDP) Appeals

A Collection Due Process appeal is available when the IRS issues certain "final" notices, including:

A Notice of Intent to Levy (typically sent as Letter 1058 or LT11).

A Notice of Your Right to a Hearing (often included with a levy notice or a Notice of Federal Tax Lien).

A denial of an installment agreement request.

A proposed termination, modification, or rejection of an existing installment agreement.

To exercise this right, you must file Form 12153, Request for a Collection Due Process or Equivalent Hearing, within 30 days of the date on the IRS notice. If you miss the deadline, your appeal rights may be permanently lost.

Collection Action Program (CAP) Appeals

A Collection Action Program appeal is available for taxpayers who do not qualify for a CDP hearing, typically because they missed the 30-day deadline or the underlying notice was not a "final" notice.

While CAP appeals are generally less powerful than CDP hearings, they still allow taxpayers to raise legitimate disputes, propose alternatives, and in some cases obtain meaningful concessions from the IRS.

What You Can Achieve Through a Collection Appeal

A successful collection appeal can:

Release an existing levy or garnishment.

Prevent a levy, garnishment, or seizure from taking effect.

Order the IRS to withdraw or subordinate a federal tax lien.

Approve an installment agreement, Offer in Compromise, or Currently Not Collectible status.

Remedy procedural errors in the IRS collection process.

How We Help

Michelle Turpin P.C. handles the entire collection appeals process, including:

Reviewing the IRS notice and determining whether you qualify for a CDP or CAP appeal.

Preparing and filing Form 12153 within the strict 30-day deadline.

Identifying and presenting the strongest legal and factual arguments to support your case.

Representing you in any conference or hearing with the IRS Appeals Officer.

Continuing to pursue favorable resolution if the appeal is unsuccessful.