The Collection Appeals Program (CAP) is available for a broad range of collection actions. However, you can’t go to court if you disagree with the Appeals decision.
If you disagree with an IRS collection action, such as a tax lien, levy, or IRS denial of your request for an installment agreement or offer in compromise, you can request a Collection Appeals Program (CAP) hearing with the IRS Office of Appeals.
During the hearing, you or your authorized representative will state your case and provide documentation to support your position. It’s generally a quick process, but you can’t appeal the outcome in court if you disagree with it. The IRS notice you receive will explain any of your available appeal rights and will give you a deadline to request an appeal.