CP15: Notice of penalty charge (civil penalty assessed)

What CP15 is

Tells you the IRS has assessed a civil penalty that isn't subject to deficiency procedures and how much you owe. In the information-return context it usually follows a 972CG you didn't answer, or answered unsuccessfully. It carries appeal rights.

The deadline

Pay by the date shown, or request abatement / file an appeal, generally within 30 days of the notice date to preserve appeal rights before collection starts. Interest runs from the assessment.

What to do

If you never responded to the 972CG, you can still request abatement for reasonable cause with the same statement and exhibits; if you did respond and were denied, this is where you appeal.

CP15, CP215 and where the 972CG went

CP15 and CP215 are the same bill on two different kinds of account: CP15 issues on an individual (IMF) account and CP215 on a business (BMF) account. A sole proprietor who files 1099s under a Social Security number, or a partnership or trust whose penalty posted to the individual side, receives the CP15; a corporation or LLC with an EIN receives the CP215. Either way it is the assessment of a civil penalty that does not go through deficiency procedures, which for a payer almost always means an information return penalty under IRC 6721 or 6722 after a Notice 972CG. The 972CG proposed the penalty and gave 45 days; the CP15 means the 45 days passed without a response, or the response was considered and the penalty sustained, in which case a Letter 854-C explaining the denial should have come first. Interest runs from the date on the CP15, and a balance that is not paid or disputed moves to CP504 and then to a levy letter.

Paying, disputing, or both

If you never answered the 972CG, the reasonable-cause case can still be made now, to the unit that assessed the penalty, with the same elements the 972CG asked for: a statement signed under penalties of perjury explaining what caused each failure, what you did when you found out, and what you changed, with the solicitation records, B-Notice copies and W-9s attached. For missing or incorrect TIN penalties the records are the case; a payer that solicited the TIN properly and can show it is entitled to the waiver. If you did answer and were denied, the CP15 is the point to appeal, and the 854-C that preceded it tells you the stated reason to cure. Pay any part you do not dispute so interest stops on it, ask in writing for a collection hold while the request is pending, and if the balance is small relative to the cost of the dispute, consider paying and filing a Form 843 claim for refund, which carries Appeals and suit rights that an unpaid abatement request does not. The response guide covers what the examiner checks, and the after-the-denial guide covers the reconsideration and Appeals routes.

Questions about CP15

Have a different notice? The IRS notice decoder lists all 77 in the order they tend to arrive.