That is where IRS Form 15237-A comes in. If you prevailed and meet the rules, you can ask the IRS to reimburse reasonable administrative or litigation costs under Section 7430 that are tied to lien and levy related actions under Sections 7426(h), 7432, and 7433. The IRS created a dedicated, fillable PDF for that request, Form 15237-A, last posted in February 2020, and it still appears in the official forms directory today.
Plain English, if the IRS caused a lien or levy problem and you were the prevailing party, Form 15237-A is the paper trail you use to request back eligible costs from that fight, subject to specific timing, eligibility, and documentation rules.
I am writing to you as if we were at your conference table, because this is a Your Money or Your Life topic. The guidance below reflects IRS sources reviewed through December 17, 2025, and I include citations so you can confirm each time‑sensitive rule before you file.
Key takeaways
- Form 15237-A is the IRS’s fillable request to claim reasonable costs under IRC §7430 when your claim relates to lien or levy actions under §§7426(h), 7432, or 7433. The current listed revision is 02‑2020 and the file still lives on IRS.gov.
- You must be a prevailing party, meet §7430 net worth and party‑size limits, and you must file your written cost request within 90 days after the IRS mails a final adverse decision on your administrative claim, or treat six months of inaction as a denial for court review. Weekends and holidays roll under §7503.
- Damages for wrongful levy or unauthorized collection have caps in court, generally the lesser of 1,000,000 or your actual direct economic damages, 100,000 if negligence, plus the costs of the action if you succeed, but those costs are not paid in the administrative claim. You use §7430 to pursue cost recovery.
- Send administrative claims and related §7430 requests to the IRS Area Director, Attention, Collection Advisory Group Manager, for the correct state office, and use Publication 4235 to confirm the current address. Mail by certified or registered mail, or deliver by personal service. Publication 4235 was updated in July 2025.
- Two‑year statutes apply to damages claims under §§7426(h) and 7433, and you may sue after six months of inaction on a processable claim. For §7432 failure‑to‑release‑lien, you may sue after 30 days of inaction, but the overall limit remains two years from accrual.
What is IRS Form 15237-A
Form 15237-A, Request for Section 7430 Recoverable Costs, is a fillable IRS PDF you use to ask for reasonable costs when you substantially prevailed in an IRS administrative proceeding connected to a lien or levy issue. The form is part of the damage‑claim ecosystem the IRS set up alongside Publication 5390, which provides instructions and includes the companion Form 15237 for administrative damages. Even though the IRS regulations do not force you to use a specific format for §7430 requests, the Internal Revenue Manual points claimants to Form 15237-A for cost claims tied to §§7426(h), 7432, and 7433.
Where you file matters. The IRS says to address these administrative submissions to the Area Director, Attention, Collection Advisory Group Manager, for the state where the claimant resides or where the corporate headquarters sits. Publication 4235 lists the current Advisory addresses. Use certified or registered mail, or personal service. Keep your proof of mailing.
What goes in the package is just as important as the form. The request should clearly identify you, your case, why you prevailed, and a fully itemized set of costs with invoices and time records. Regulations under §7430 explain the 90‑day post‑decision clock and what a “final adverse decision” means, for example a Form 870 closing agreement, a notice of assessment, or the Appeals decision that resolves your liability.
A quick word on search intent
If you landed here looking for “IRS Form 15237-A” or “Section 7430 administrative costs,” your goal is simple, learn whether you qualify, what you can recover, where and when to file, and how to assemble proof that will not get bounced for being incomplete. That is exactly what you will get below, plus plain‑language steps and the exact deadlines the IRS uses internally to evaluate these claims.
Who can use this form
You can use Form 15237-A when you meet all three conditions.
- You are a prevailing party, you substantially prevailed on the amount in controversy or on the most significant issues.
- You meet the net‑worth or size limits under §7430 and you did not previously present the same underlying issues to a U.S. court before your administrative request.
- You file your written cost request, with affidavits and itemization, within 90 days after the IRS mails its final adverse decision on your administrative claim, or, if the Service does not respond within six months, you treat that inaction as a denial for purposes of Tax Court review of the cost request.
In practice, the IRS’s own manual reminds employees that, after a denial of a damages claim, the claimant has 90 days to submit a §7430 cost claim and that Form 15237-A is the reference template. That is your timing anchor.
Eligible damages and cost recovery, what you can and cannot claim
Here is the split most people miss, there are two parallel tracks.
- Track 1, administrative damages under §§7426(h), 7432, and 7433, which focus on actual, direct economic damages from wrongful levy, failure to release lien, or unauthorized collection.
- Track 2, recoverable costs under §7430, which cover reasonable administrative or litigation costs for the action, for example attorneys’ fees, expert witness fees, and necessary studies or reports, but only when you are the prevailing party and you meet all the other conditions.
Damages caps for wrongful levy or unauthorized collection
If you ultimately sue and win in federal district court under §7426(h) or §7433, your damages are capped at the lesser of 1,000,000, or 100,000 in negligence cases, or your actual direct economic damages caused by the IRS’s actions, plus the costs of the action. Administrative claims inside the IRS pay only actual direct economic damages, not litigation or administrative costs. You pursue those costs through §7430.
Direct economic damages are fact based, for example a lost sale caused by an erroneous NFTL, an interest rate bump on a loan because of a wrongful levy, or concrete repair and replacement costs after a seizure mistake. Every dollar needs backup. The IRS expects schedules, contracts, bank statements, cancelled‑sale records, and third‑party corroboration where relevant.
What qualifies as “recoverable costs” under §7430
Reasonable administrative costs can include fees for your representative before the IRS, necessary expert work, and certain studies or analyses. Reasonable litigation costs include court costs, expert witnesses, printing and transcripts, and attorneys’ fees, all subject to §7430 rules. The timing rule is strict, you must file your written cost request within 90 days after the IRS mails its final adverse decision in the underlying administrative matter.
A few practical notes I give clients:
- Keep time records that look like real billing. The regs even talk about pro bono time records needing the same level of detail.
- Tie each time entry or invoice to a specific task in the IRS matter.
- If you are using a specialist with distinctive skills, document why those skills were necessary and not widely available.
Deadlines and periods of limitation you cannot miss
Think in layers.
- The two‑year clock for damages suits under §§7426(h) and 7433 starts when you had a reasonable opportunity to discover all essential elements of the claim, not necessarily the day the IRS took the action. If the IRS does not issue a determination within six months of a processable claim, you may sue.
- For §7432 failure‑to‑release‑lien, you must file an administrative claim and you may sue once 30 days pass without a decision, but the overall statute is still two years from accrual.
- For §7430 costs, the key is the 90‑day rule after the IRS mails its final adverse decision in your administrative case. If the IRS does not respond to your written §7430 request within six months, that inaction can be treated as a denial for court review. Weekends and legal holidays adjust under §7503.
Quick reference table
| Statute | When you can sue early | Overall limit | Notes |
| §7432 | 30 days after filing a processable admin claim with no decision | 2 years from accrual | Failure to release lien claims, admin claim is required. |
| §7426(h) | 6 months after a processable admin claim with no decision | 2 years from accrual | Third‑party wrongful levy related damages. |
| §7433(a–d) | 6 months after a processable admin claim with no decision | 2 years from accrual | Unauthorized collection by IRS employees. |
| §7430 costs | After final adverse decision, file within 90 days, or treat 6 months of inaction as denial for review | N/A | Use Form 15237‑A for lien or levy related matters. |
Where and how to submit your claim
- Address the administrative claim and any follow‑on §7430 cost request to the IRS Area Director, Attention, Collection Advisory Group Manager, for the correct location. Publication 4235 lists current Advisory offices, and it was refreshed in July 2025, which is why I always verify addresses the day I mail.
- Send by certified or registered mail, or deliver by personal service, and keep the proof of mailing. That single receipt often decides whether a claim is considered timely if dates are tight.
Pro tip, if your claim involves a Notice of Federal Tax Lien, include a copy of the NFTL and any prior lien release or withdrawal requests. It shortens the internal review.
Section‑specific claim requirements, how to tailor your package
Every statute has its own elements. Your Form 15237‑A request should mirror them so the reviewer finds exactly what they need.
Section 7426(h), third‑party wrongful levy, surplus proceeds, or substitution disputes
Who you are, typically not the taxpayer but a third party with a legal interest in the property. What you must include, identity details, a clear factual basis with dates, the levy or sale documents, and an itemized dollar amount for actual direct economic damages that were foreseeable and caused by the IRS action. Where to send it, the Area Director, Attention, Collection Advisory Group Manager for the state at issue.
Put yourself in the reviewer’s chair. If you claim lost profits from a blocked sale, include the signed purchase agreement, buyer correspondence, title report showing the NFTL appearance, and lender or escrow communications that document the fallout. The IRM tells reviewers to verify when you knew, or should have known, about the violation because that drives the two‑year statute clock.
Section 7432, failure to release lien
The regulation is explicit, you cannot sue before you first file an administrative claim, and you may sue after 30 days if there is no decision. For filing, include a copy of the NFTL, the prior release request, and proof that release was due under §6325. If you cannot locate the right office, Publication 4235’s Collection Advisory list is your map.
A simple outline works well here, timeline of the lien and your release request, why release was required, what went wrong, and each dollar of direct economic damages that you can prove with documents. The IRM even lists the letters IRS uses to deny or allow a §7432 damage claim. Do not guess at dates, use stamped or system‑dated files.
Section 7433(a–d), unauthorized collection by IRS employees
Identify the taxpayer and TIN, describe the unauthorized actions with dates, IRS employee identifiers if you have them, and attach all related notices and correspondence. Itemize actual direct economic damages with calculations and backup. You can sue after six months of inaction, while the two‑year statute runs from accrual.
Step‑by‑step instructions to complete Form 15237‑A
Here is a practical flow that keeps reviews fast and predictable.
Gather required information
- Identification, claimant and taxpayer if different, names, addresses, TINs, contacts.
- Your statutory hook, check the box that matches your underlying section, §7426(h), §7432, §7433, and that the cost claim is under §7430.
- Itemized costs, attorneys’ fees, expert fees, and studies or reports. Use time entries with dates, rates, and descriptions.
- Evidence, lien or levy notices, release requests, correspondence, contracts, appraisals, loan term sheets, bank statements, photographs, and sworn statements where needed.
I like to create a one‑page index of exhibits so a reviewer can match every line item to a document. It sounds basic, but it is the difference between a quick yes and a month of back‑and‑forth.
Complete the claim sections
- Section 1, claimant and taxpayer details, including TINs and contacts.
- Section 2, total costs you request under §7430, how you computed them, and your damages summary if relevant to tie the story together.
- Section 3, check the applicable statute box that connects your cost request to §7426(h), §7432, or §7433.
- Sections 4–5, a clear factual basis, legal hook, and an itemized breakdown with dates, rates, and calculations.
- Sections 6–7, list every attachment, sign and certify under penalty of perjury, and include your representative’s authorization if applicable.
Submit and track deadlines
- Start with the final IRS decision date in your underlying administrative matter, then count 90 days for the §7430 cost request window. If the IRS does not respond within six months to your cost request, treat it as a denial that you can bring to court.
- For damages statutes, calendar the two‑year accrual deadline and the six‑month inaction rule. For §7432, calendar the 30‑day inaction rule. Set a 14‑day and 7‑day reminder for mailing so you do not cut it close.
Documentation that strengthens your claim
When the IRS reviews these files, they look for three things, did you identify the IRS action, did you prove real economic harm with documents, and did you submit on time to the right place. Build your package with that lens.
- IRS notices and correspondence, for example, NFTLs, levy notices, Appeals letters, final denials, and certified‑mail proofs. These show the timeline and the agency’s actions.
- Itemized invoices and time records, for attorneys, enrolled agents, and experts. Use hourly rates, dates, tasks, and totals that add up to the number you request on Form 15237‑A, because the regulation expects specificity.
- Proof of direct economic damages, contracts, cancelled‑sale documents, lost rent schedules, lender letters showing rate or term changes tied to the IRS issue, repair estimates, appraisals, and bank statements. Tie each exhibit to a numbered fact in your narrative.
If a cost or damage entry looks like an estimate, state why it is reasonably foreseeable and show how you will compute it when incurred. The IRM notes that estimates can be included, but reviewers will expect logic and math, not round numbers.
Downloading the fillable PDF and getting it right
Always download the official file from IRS.gov to avoid stale templates. The IRS directory shows Form 15237‑A with a February 2020 posting. If your browser displays a “please wait” message, open it in Adobe Acrobat Reader so the fields render correctly. Save a clean copy with your entries, and keep a PDF of every exhibit.
Where to download
- Search the IRS Forms and Publications site for “Form 15237‑A,” or go directly to the IRS static files directory that lists f15237a.pdf with the 02‑2020 timestamp. Verify the filename matches f15237a.pdf.
- Publication 5390, which the IRS uses to guide claimants, sits in the same directory if you need the broader administrative claim instructions and companion Form 15237.
Fillable PDF steps
- Open in a current PDF viewer, complete all fields, and use consistent names across the form and exhibits.
- Cross‑reference each line in your itemized cost list to an invoice or time record.
- Sign under penalty of perjury, attach your exhibit index, and, if represented, include the authorization your reviewer will expect to see.
- Print to PDF to create a final, locked package for mailing. Keep a digital set for your records.
Submission deadlines, the short list
- §7430 costs, file within 90 days after the IRS mails the final adverse decision on your administrative claim. If six months pass without a decision on your written §7430 request, you can seek court review.
- §7426(h) and §7433 damages, you may sue after six months of inaction, but never beyond two years from accrual.
- §7432 failure‑to‑release‑lien, you may sue after 30 days of inaction, within the same two‑year period.
Step‑by‑step example you can model
Imagine you received an erroneous NFTL that spooked a buyer. You filed a proper administrative claim for damages and later received a denial. You substantially prevailed after presenting the facts to IRS Appeals, and now you want your costs back.
- Day 0, Appeals mails its final decision that resolves liability in your favor. Start your 90‑day §7430 clock.
- Days 1–14, collect invoices and time records, write a short narrative that links dates, actions, and costs, and prepare Form 15237‑A.
- Day 15, send your §7430 package to the correct Advisory office from Publication 4235, by certified mail, return receipt requested.
- Day 60, if the IRS asks for clarifications, respond in writing and add exhibits if needed.
- Day 180, if no decision yet, understand that inaction past six months can be treated as a denial for court review of the cost request. Track your options with counsel.
FAQs
Is Form 15237‑A mandatory for §7430 requests?
No specific format is required by regulation for a §7430 request. The IRS, however, directs claimants handling lien or levy related matters to use Form 15237‑A, and it publishes that form alongside Publication 5390. Using the IRS template reduces the risk of a “not processable” response.
Where exactly do I mail my package?
Mail or deliver to the IRS Area Director, Attention, Collection Advisory Group Manager for your state. Publication 4235 lists current addresses, refreshed July 2025. Use certified or registered mail and keep receipts.
What counts as a “final adverse decision” that starts the 90‑day clock?
The regulations say it is the document that resolves your liability for all amounts at issue, for example a Form 870 closing agreement, an Appeals final decision, or a notice of assessment, whichever is furnished first. That mailing date starts the 90‑day window for your §7430 request.
Can I include estimated costs?
Yes, if they are reasonably foreseeable and directly related. Spell out your assumptions and show how you will calculate the final amount. The IRS discusses including reasonably foreseeable amounts in both Publication 5390 and the IRM.
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