IRS Notice CP15 — Civil Penalty Notice and How to Fight Back
A Notice CP15 lands in your mailbox and the first thing you notice is the word "penalty." The IRS has assessed a civil penalty against you — and depending on the type, it can add thousands of dollars to what you owe. This isn't the moment to panic. It's the moment to understand exactly what the IRS is claiming and whether you have grounds to appeal it.
What Cp15 Means
CP15 is an assessment notice for a civil penalty under a range of Internal Revenue Code provisions. The most common triggers include:
Frivolous return penalties under IRC § 6702 — the IRS fines you $5,000 if it determines you filed a return with a "frivolous" position to reduce your tax liability.
CP15B — a variation assessing Trust Fund Recovery Penalties against business owners for unpaid employer payroll taxes.
Accuracy-related penalties under § 6662 for substantial understatements of income.
The penalty type is spelled out in the notice itself. Read it carefully before responding.
Your Right To Appeal
You have the right to dispute this penalty. For most civil penalties, you must file a written protest with the IRS Office of Appeals within 30 days of the notice date. Your protest needs to identify the specific penalty, explain why it should be abated or reduced, and cite any relevant IRC sections or case law supporting your position. A generic letter won't cut it — the IRS Appeals process rewards specifics.
Your 3-Step Action Checklist
Identify the penalty type. The notice will reference the specific IRC section. Know what you're dealing with before you respond.
File a written protest. You have 30 days. State clearly why the penalty is improper or request reasonable cause abatement if the error was genuine and not willful.
Consult a tax attorney. Frivolous return penalties and Trust Fund assessments carry serious downstream consequences. An attorney can evaluate your protest and represent you in Appeals.
What Happens If You Ignore It
The penalty becomes final and the IRS begins collection. For business owners hit with a CP15B / Trust Fund Recovery Penalty, the stakes are even higher — the IRS can pursue you personally for a company's unpaid payroll taxes, piercing the corporate veil entirely.
How We Can Help
Our attorneys have successfully protested and abated IRS civil penalties for individuals and business owners across a wide range of circumstances. We evaluate whether the penalty was properly assessed, whether reasonable cause exists, and whether First-Time Abatement or administrative relief applies.
Call us before the 30-day window closes. Missing the deadline eliminates your administrative appeal rights.