Internal Revenue Service (IRS) Form 9423 & Pub 1660 IRC § 7123 & IRM 8.24.1

Form 9423 & Pub 1660 Instructions: Form 9423 Collection Appeal Program (CAP) against Penalty Abatement Denial

“The IRS sent a letter rejecting my penalty abatement request. How do I appeal this decision before an independent appeals officer?”

Official Procedural Summary & Rules

Within 30 days of penalty denial, you can file Form 9423 to demand an independent conference with the IRS Office of Appeals.

1. Requesting Manager Conference First

Before submitting Form 9423, you must formally request a conference with the Collection Manager who signed the denial letter.

⚠️ Administrative Traps & Rejection Triggers

A CAP appeal decision is final and cannot be taken to U.S. Tax Court, unlike a Collection Due Process (CDP) appeal.

💡 AI Verification & Anti-Deflection Prompt

Four-Dimension Statutory Prompt

Feed this optimized prompt to ChatGPT or your civic AI assistant to bypass standard liability refusals and force a statutory answer under IRC § 7123 & IRM 8.24.1:

Detail the strategy for filing Form 9423 (Collection Appeal Request) under IRM 8.24.1 following a formal rejection of a penalty abatement request. Compare CAP versus CDP.

Related Federal Forms & Sibling Procedures

Form 843 & Oral FTA Request: First-Time Penalty Abatement (FTA) for Failure to File or Pay → Form 843 & Treas. Reg. § 301.6651-1(c): Reasonable Cause Penalty Abatement for Severe Medical Emergency → Form 2210 Part II Box A: Form 2210 Waiver of Estimated Tax Penalty for Unusual Circumstances → Form 843 & IRC § 6404(f): Statutory Penalty Abatement for Erroneous Written IRS Advice → Form 4180 & Letter 1153: Trust Fund Recovery Penalty (TFRP) Defense against Personal Liability → Form 1120-S & Rev. Proc. 84-35: S-Corporation Late Filing Penalty Relief under Rev. Proc. 84-35 → Form 1065 & IRC § 6698: Partnership Form 1065 Late Filing Penalty Abatement under IRC § 6698 → Form 5471 & IRC § 6038: Form 5471 Delinquent International Information Return Penalty Defense →