b. Streamlined $50,000, or less c Over $50,000
5. CAP Hearing
Cannot use CAP to challenge underlying tax assessment But can be used to challenge the liability; also will not consider trust fund recovery penalties, offers in compromise, or penalty abatement appeals
> during the period that a request for an installment agreement is pending; > during the 30day period following rejection of the request; > during the period that an installment agreement is in effect; > during the 30day period following termination of an agreement; and > if such rejection or termination is appealed, during the period the appeal is pending.4 May contest before or after: a. Notice of Federal Tax Lien b. Notice of Levy c. Seizure of Property d. Rejection of Termination of Installment Agreement e. Wrongful Levy
4
Freezes Collection Activity
A $5,000 penalty may be imposed for submitting an installment agreement request that is frivolous or designed merely to impede or delay tax administration. See ยง6702(b). No penalty applies if a taxpayer withdraws a frivolous application within 30 days of being so notified. ยง6702(b)(3). The penalty also may be reduced at the IRS's discretion. ยง6702(d). A frivolous application also may be treated as if it never were submitted, thus precluding further administrative or judicial review
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