IRS Notice CP15 is a formal notice telling you the IRS has assessed a specific civil penalty against your account and you owe the amount shown by the due date on the notice. It is not a recalculation of your tax return or a correction of a math error. It is a standalone penalty charge, most often tied to unpaid employment taxes (the trust fund recovery penalty, delivered on the variant CP15B) or to a missed international information return such as Form 5471, 5472, or 8938. Interest starts running from the date on the notice, and the procedures for contesting these penalties are stricter than the ones you may have seen for ordinary tax disputes.
Figure Out Which Penalty You Were Charged
The notice names the Internal Revenue Code section, the tax period, and the dollar amount. That combination tells you what you are actually dealing with, because the rules for responding depend on it.
Trust Fund Recovery Penalty (CP15B)
If your notice is a CP15B, the IRS has personally assessed you for income tax, Social Security, and Medicare that an employer withheld from employee paychecks but failed to turn over to the government. Under 26 USC 6672, a “responsible person” who willfully failed to pay those trust fund amounts can be held liable for 100% of the unpaid portion.1Office of the Law Revision Counsel. 26 USC 6672 – Failure to Collect and Pay Over Tax, or Attempt to Evade or Defeat Tax The IRS reads “responsible person” broadly, reaching corporate officers, shareholders with financial authority, partners, LLC members, and sometimes bookkeepers or payroll providers who decided which bills got paid.2Internal Revenue Service. Internal Revenue Manual 8.25.1 – Trust Fund Recovery Penalty Overview and Authority The penalty can be assessed against more than one person for the same unpaid taxes, and it survives bankruptcy.
International Information Return Penalties
CP15 is also the vehicle for penalties on missed foreign reporting forms. These are assessed manually and escalate quickly:3Internal Revenue Service. International Information Reporting Penalties
- Form 5471 (ownership in a foreign corporation): $10,000 per failure, plus $10,000 for each 30-day period you remain non-compliant after a 90-day warning, capped at $50,000 in continuation penalties.
- Form 8938 (foreign financial assets): $10,000 per failure, same 30-day continuation structure, capped at $50,000.
- Form 5472 (foreign-owned U.S. corporations): $25,000 per failure, with $25,000 continuation penalties every 30 days after the 90-day notice period and no maximum.
People living abroad, dual citizens, and immigrants with accounts or interests back home often learn about these filing duties for the first time through a CP15.
Other Information Return Penalties
CP15 occasionally appears for domestic information return problems — late or improperly formatted Forms 1099 or W-2, for instance — when the penalty is assessed manually rather than through the automated Notice 972CG process.4Internal Revenue Service. Internal Revenue Manual 20.1.7 – Information Return Penalties
Read the Notice Before You Do Anything Else
Find the notice date and the payment due date near the top. Interest runs from the notice date, and the due date controls your response window. Note the Code section cited for the penalty; that tells you which rules govern your options.
Check that the tax periods on the notice line up with reality. For a trust fund recovery penalty, confirm the quarters match times when you actually had authority over the business’s money. For international reporting penalties, confirm you had a filing obligation for the years listed — people sometimes get CP15 notices covering years after they divested from a foreign corporation or closed a foreign account.
Write down the direct phone number and mailing address printed on the notice. The general IRS line will route you back to this unit anyway, and starting there costs you an hour on hold.
If You Agree, Pay by the Due Date
Interest accrues at 7% per year, compounded daily, as of the first quarter of 2026, and runs from the notice date until the balance is paid in full.5Internal Revenue Service. Interest Rates Remain the Same for the First Quarter of 2026 You can pay through the IRS online payment portal, by phone, or by mail using the voucher that came with the notice.
If you cannot pay in full, an installment agreement keeps the IRS from escalating collection action, though it does not stop interest. Individuals owing $50,000 or less in combined tax, penalties, and interest can apply for a long-term payment plan online. Larger balances require Form 9465 and often a Form 433-F financial statement.6Internal Revenue Service. Payment Plans – Installment Agreements
If You Disagree, the Procedure Depends on the Penalty
Fighting a Trust Fund Recovery Penalty
You cannot contest a TFRP by simply writing a letter saying you disagree. To preserve your right to challenge it in court without first paying the full amount, you have to do two things:
- Make a partial payment equal to the withheld tax attributable to one employee for each quarter the penalty covers. If the penalty is for excise taxes, pay the tax from one transaction per quarter.
- File a separate Form 843 (Claim for Refund and Request for Abatement) for each quarter at issue.
If the IRS denies the Form 843 claim, you can then sue in federal district court or the Court of Federal Claims.7Internal Revenue Service. Understanding Your CP15B Notice
Stopping IRS collection while your case is pending takes more. In addition to the partial payment and Form 843, you must post a bond equal to one and a half times the balance remaining after your partial payment is applied.7Internal Revenue Service. Understanding Your CP15B Notice That bonding requirement is a serious hurdle, which is one reason TFRP disputes are usually fought earlier in the process.
Fighting Other CP15 Penalties
For international reporting penalties and other non-TFRP assessments on a CP15, respond in writing by the deadline on the notice. Send your letter to the specific address printed on the notice (not a general IRS processing center), with a copy of the notice, a plain explanation of why the penalty is wrong or should be removed, and copies of any supporting documents.
You can also request abatement by calling the number on the notice or by filing Form 843. The instructions for Form 843 direct you to follow any contest procedure already spelled out in your notice first; Form 843 is not always required.8Internal Revenue Service. Instructions for Form 843 Whatever route you take, send it certified mail with return receipt. If the IRS later says you missed the deadline, that receipt is your proof.
Ask for Penalty Relief Even If the Violation Happened
First Time Abate
If your compliance history is clean, the IRS may wipe the penalty under its First Time Abate policy. You qualify if you filed the same type of return for each of the three years before the penalty year and had no penalties during those three years (or any prior penalty was removed for an acceptable reason). You do not need to send documentation — the IRS pulls your account history.9Internal Revenue Service. Administrative Penalty Relief
One important limit: First Time Abate does not apply to penalties with event-based filing requirements.9Internal Revenue Service. Administrative Penalty Relief Many international information return penalties fall in that category, so this relief often is not available for the exact penalties that produce the largest CP15 bills. Call the number on your notice to request it. If you ask for reasonable cause relief but actually qualify for First Time Abate, the IRS applies the First Time Abate automatically.
Reasonable Cause
Reasonable cause relief is available when you exercised ordinary care and prudence but could not comply because of circumstances beyond your control. Serious illness, natural disasters, destruction of records, and reliance on incorrect advice from a tax professional are the usual examples. You can request it by phone using the number on the notice; if that does not resolve it, follow up with Form 843 and documentation.10Internal Revenue Service. Penalty Relief for Reasonable Cause
What Happens If You Ignore the Notice
Interest keeps compounding daily at 7% per year.5Internal Revenue Service. Interest Rates Remain the Same for the First Quarter of 2026 After that, the IRS moves to collection: federal tax liens against your property, bank levies, wage garnishment. Before levying, the IRS must send a separate Notice of Intent to Levy, which gives you 30 days to request a Collection Due Process hearing.11Internal Revenue Service. Collection Due Process (CDP) FAQs
A CDP hearing lets you propose alternatives such as an installment agreement or an offer in compromise, and in limited situations you can still dispute the underlying penalty if you had no earlier chance to do so.11Internal Revenue Service. Collection Due Process (CDP) FAQs Waiting that long is expensive, though. By the time collection notices arrive, months of interest have already stacked on top of the original penalty.
When to Hire a Professional
A CP15 is not the kind of notice you fix with a quick phone call. Trust fund recovery penalties routinely reach six figures, attach to you personally, and are not discharged in bankruptcy. International reporting penalties stack across forms and years. For either category, bring in a tax attorney or an enrolled agent who handles IRS penalty work. The partial-payment-and-refund-claim procedure for TFRPs in particular has strict mechanics, and a wrong step can cost you the right to contest the penalty in court at all.