Currently Not Collectible (CNC) status can provide you with temporary relief from tax debt collection efforts by the IRS. However, if you applied for but were denied CNC status, all hope is not lost, as you have the option to appeal this ruling. A tax attorney can be a great ally during this process as appeals are often complex and can take months to complete.
When the IRS first initiates a collection action on your tax debt, such as in the form of a tax lien or a levy on your bank account, you have the option of trying to stop it through an appeal. Appealing a CNC determination is a very similar process. In addition to requesting review of collection actions, you may ask the IRS to review your CNC determination. You may request a Collection Due Process (CDP) hearing, or pursue the Collection Appeals Program (CAP). You might choose the CAP process because it is faster, but bear in mind that the decision is final and cannot be reviewed by the Tax Court.