CP215 (Form 8278 penalties): Notice of Penalty Charge, business: the bill for an assessable penalty, with no proposal stage before it

What CP215 (Form 8278 penalties) is

The BMF civil-penalty notice, generated when a penalty assessed on Form 8278 posts to MFT 13 (IRM 20.1.9.1.5(15), Jan. 29, 2021). It opens "We charged you a penalty under section", names the IRC section through the penalty reference number that "dictates the explanatory language in the assessment notice," shows a balance table with payment options and claim-for-refund instructions, and on page two carries "standard language that advises the taxpayer on what to do if his or her refund claim has been pending for more than six months" (Exhibit 20.1.9-7; IRM 20.1.9.1.5(2)). For an assessable penalty "there is no 30-day letter, no agreement form, and no notice requirements prior to assessment," so for a penalty such as IRC 6705 (PRN 632), 6674 (PRN 575), 6652(a) (PRN 590) or 6652(l) (PRN 649) this may be the first document you receive.

The deadline

Pay by the date shown, or file a written appeal request; "Appeals currently provides a prepayment, post assessment appeal process" under IRM 8.11.5 (IRM 20.1.9.1.5(5)). Interest runs from the notice.

What to do

Read the section number and PRN and look them up in the decoder. For PRN 632 or 575 there is no reasonable-cause request to write; "the taxpayer must fully pay the entire penalty and then file a claim for refund" (IRM 20.1.10.13.3, 20.1.10.9.3, Oct. 12, 2022). For the others, send a written request to the unit that assessed it, under penalties of perjury; First Time Abate and oral requests do not apply to any penalty in IRM 20.1.10 (IRM 20.1.10.2.2(3), 20.1.10.2.5). Ask in the same request for the supervisory approval record; the manual requires the originator and supervisor to sign every page of the Form 8278 (IRM 20.1.10.2(9), Aug. 12, 2026).

What a CP215 is billing you for

CP215 is the business version of the civil penalty bill: the notice that a penalty has been assessed on your account and is due. For a payer the usual penalty behind it is the information return penalty under IRC 6721, which means that the Notice 972CG you received a year or more earlier has run its course. Either no response was received within the 45 days, or the response was considered and the penalty was sustained in whole or in part, in which case a Letter 854-C explaining the denial should have come first. The CP215 names the Code section and the penalty reference number, shows the amount, the interest accrued since the assessment date and the payment due date, and explains how to claim a refund. For some other penalties there is no proposal stage at all and the CP215 is the first document a payer sees; the PRN decoder identifies which from the reference number.

Interest runs from the date of the notice and demand, and the balance follows the normal collection path (CP504, then the levy letter) if it is neither paid nor contested.

Paying, appealing, or both

There are three ways to respond and they are not exclusive. Pay the balance through EFTPS, tagging the payment as a civil penalty for the year shown, and the matter is closed unless you claim a refund. Contest it without paying by sending a written reasonable-cause request to the unit that assessed the penalty (the notice gives the address), signed under penalties of perjury, with the solicitation records, B-Notice copies and other exhibits a 972CG response would have carried; for a payer who missed the 972CG window this is the first and best chance to make the case, and for one whose 972CG response was denied it is a reconsideration request that should add what the denial letter said was missing. Or pay and then claim the refund on Form 843, which is the only route for the handful of penalties that have no reasonable-cause defense at all. A penalty sustained after reconsideration can be taken to the IRS Independent Office of Appeals after assessment; the Appeals guide covers how, and the no-defense penalties page lists the ones where only the refund route is open. Whichever you choose, ask in writing for a collection hold while the request is pending, and pay any part you do not dispute so that interest stops on it.

Questions about CP215 (Form 8278 penalties)

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