Office of Appeals – Hearing available Under Collection Appeals Program (CAP) (Part IV):
Collection actions you may appeal under CAP – Wrongful Levy:
If you are not liable for tax and the IRS has levied or seized property that you believe belongs to you or in which you have an interest superior to the IRS, you may appeal the denial by the IRS of your request to release the levy or seizure, or return the property or its value.
Please note that a request to the IRS to return wrongfully levied property must be in writing, filed within 9 months of the levy or seizure if it was made on or before March 22, 2017, and must satisfy certain requirements. If the levy or seizure was made on or after March 23, 2017, your request must be made within 2 years from the date of the levy or seizure.
See Publication 4528, Making an Administrative Wrongful Levy Claim Under Internal Revenue Code (IRC) Section 6343(b) on the www.irs.gov web site.
Next week – How to appeal if contacted by notice or telephone call
(IRS Publication 1660) (TTT 05/07/19)