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Winning the underlying fight with the IRS does not hand you your costs back automatically. Form 15237-A is the request a prevailing party files to recover reasonable administrative costs under section 7430, and it is a separate piece of paper from the damage claim on Form 15237.
Timing is where these requests die. File the written cost request before the 91st day after the IRS mails its final adverse decision, which means inside 90 days, and cite the current Revenue Procedure for the inflation-adjusted attorney-fee cap rather than the bare statutory base under 7430(c)(1). You also have to clear the net worth and party-size limits that section 7430 sets before any of it counts.
Key Takeaways
- Form 15237-A is the IRS’s fillable request a prevailing party files to claim reasonable administrative and litigation costs under IRC §7430. 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 under IRC §7430 when you substantially prevailed in an IRS administrative or court proceeding. Form 15237-A is exclusively the §7430 request for recoverable costs; the companion Form 15237 (no suffix) covers administrative damage claims under §§7426(h), 7432, and 7433. Even though the IRS regulations do not force you to use a specific format for §7430 requests, Form 15237-A is the IRS template for §7430 recoverable-cost requests, while damage claims under §§7426(h), 7432, and 7433 belong on the companion Form 15237 (no suffix).
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. Filing Form 15237-A does not establish this on its own, you must independently prove prevailing-party status before any costs are awarded.
- 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. Those administrative damage claims are filed on Form 15237 (no suffix), not on Form 15237-A; Form 15237-A is exclusively the §7430 request for recoverable costs and does not itself award damages.
- 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. Keep in mind, though, that a court will not award litigation costs in any proceeding unless you have first exhausted the administrative remedies available within the IRS, so winning the underlying dispute does not by itself make these costs recoverable. 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, and remember that specialized expertise alone is not automatically treated as a “special factor” under §7430, courts apply a narrow test before approving a higher rate.
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 to request §7430 recoverable costs after you prevail. |
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 stands on its own §7430 elements, prevailing-party status, exhaustion of administrative remedies, and itemized costs, 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, your cost claim is brought 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
- Identify the claimant and taxpayer, including TINs and contacts.
- State the total costs you request under §7430 and how you computed them.
- Reference the underlying administrative matter that your §7430 cost request arises from.
- Set out a clear factual basis, legal hook, and an itemized breakdown with dates, rates, and calculations.
- 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.
Common Mistakes We See Every Season
Most §7430 cost claims do not fail on the merits. They stall on timing, the wrong form, or a cap figure that was already out of date. Here are the patterns I see most.
Reusable Checklists
Paste these into your engagement SOP so every §7430 cost request leaves your desk complete, on the right form, and inside the window.
Prevailing-party eligibility check
- Confirm you substantially prevailed on the amount in controversy or the most significant issue.
- Verify the §7430 net-worth and party-size limits are met for the claimant.
- Document that the same issues were not already presented to a U.S. court before the administrative request.
- Confirm administrative remedies inside the IRS were exhausted, including Appeals.
- Note whether a §7430(g) qualified offer was made within the statutory window, from the first proposed-deficiency letter to 30 days before trial.
- Record that the claimant did not unreasonably protract the proceeding.
§7430 cost request package
- Download the current Form 15237-A (Rev. 2-2020) fresh from IRS.gov and open it in Adobe Acrobat Reader so fields render.
- Itemize attorney fees, expert fees, and necessary studies with dated time entries, rates, and task descriptions.
- Reconcile each fee line to the inflation-adjusted §7430 hourly cap from the current Revenue Procedure, not the bare $125 base.
- Attach an exhibit index that ties every cost to an invoice or time record.
- If you claim an above-cap rate, document the narrow “special factor” basis, since specialized skill alone does not qualify.
- Sign under penalty of perjury and include representative authorization if applicable.
90-day deadline tracker
- Record the mailing date of the IRS final decision; that date starts the clock.
- Calendar the request to be filed before the 91st day, which is within 90 days.
- Adjust for weekends and legal holidays under §7503.
- Set mailing reminders 14 and 7 days before the cutoff.
- Send by certified or registered mail and keep the proof of mailing.
- Calendar the six-month mark in case IRS inaction must be treated as a denial for court review.
Keep 15237-A Season From Stalling
Form 15237-A is not a seasonal filing, and that is exactly what makes it easy to drop. A §7430 cost request only lands on your desk after a client has already prevailed in an IRS dispute, and the clock to file runs before the 91st day after the IRS mails its final decision, which leaves a 90-day window with no room to slip (per IRC §7430 and the IRS forms index, where the form still shows its February 2020 revision).
The work that decides these claims is documentation, not drafting. When the time records, the prevailing-party analysis, and the inflation-adjusted fee cap are assembled in a disciplined order, the request mails on time and survives review. When they are not, the claim stalls or misses the window entirely.
- Pin the IRS final-decision mailing date the moment it arrives and back-calculate the 90-day deadline, adjusting for §7503 weekends and holidays.
- Reconcile every attorney and expert time entry to the current-year inflation-adjusted §7430 cap, not the bare $125 statutory base.
- Keep the prevailing-party and administrative-exhaustion evidence in one indexed packet so a reviewer can trace each cost to a document.
- Separate the §7430 cost request from any companion Form 15237 damage claim so neither is filed on the wrong form.
This is the kind of deadline-driven, evidence-heavy execution that benefits from a structured second set of hands. Our tax execution team builds the time-record reconciliations, exhibit indexes, and deadline calendars that keep a §7430 request moving, so the partner reviewing it spends minutes confirming rather than hours rebuilding.
FAQs
Is Form 15237‑A mandatory for §7430 requests?
No specific format is required by regulation for a §7430 request. The IRS provides Form 15237‑A as the template for §7430 recoverable-cost requests. 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.
Is there a cap on the attorney fees I can recover?
Yes. Reasonable fees for the services of attorneys are recoverable, but those fees generally cannot exceed $125 per hour under IRC §7430, subject to the statute's cost-of-living and special-factor adjustments. Keep contemporaneous time records so each hour ties to a labeled exhibit.