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When to Use the IRS Collection Appeals Program
The Collection Appeals Program (CAP) is an IRS procedure available to appeal a broad range of collection actions. However, it does have some pitfalls when compared to a Collection Due Process (CDP) hearing, so consider consulting with a tax attorney if you are not sure which procedure to use.
The CAP procedure can be used to dispute the following collection actions:
• Before or after the IRS files a Notice of Federal Tax Lien