An official website of the United States Government (NON-Prod - Development Environment)A “subordination” does not remove the lien but allows other creditors to move ahead of the IRS, which may make it easier to get a loan or mortgage.
View our interactive tax map to see where you are in the tax process. It could help you navigate your way through the IRS.
A federal tax lien arises automatically if you don’t pay the amount due after receiving your first bill. The government also may file a Notice of Federal Tax Lien (NFTL) in the public records. This notifies creditors the IRS has a claim against all your current and future property and rights to property.
Generally, within five business days of filing the NFTL, the IRS will send you a Notice of Your Right to a Collection Due Process Hearing. You’ll have until the date shown on the notice to request a Collection Due Process (CDP) hearing with the IRS Independent Office of Appeals (Appeals). This deadline can’t be extended for any reason. See Publication 1660, Collection Appeal Rights, for a full explanation of the CDP process. At the CDP hearing, you may raise many issues which include proposing another way to pay your debt, and in some cases, to contest the debt itself.
Once a lien arises, the IRS generally can’t release it until you’ve paid the tax, penalties, interest, and recording fees in full or until the IRS is no longer legally able to collect the tax. However, in certain circumstances you may request relief through NFTL withdrawal, lien discharge, lien subordination, or lien release.
This notice or letter may include additional topics that have not yet been covered here. Please check back frequently for updates.
When the IRS files the NFTL in the public record, it puts your creditors on notice that the IRS has a claim against all of your current and future property and rights to property.
The lien attaches to all assets, personal or business, such as real estate, securities, vehicles, as well as future assets acquired in the period of the duration of the lien. For more information, refer to Publication 594, The IRS Collection Process.
If you file bankruptcy, your tax debt and lien may continue after the bankruptcy.
Generally, within five business days of filing the NFTL, the IRS will send you a Notice of Your Right to a Collection Due Process Hearing. You’ll have until the date shown on the notice to request a CDP hearing with Appeals. This due date can’t be extended for any reason. See Publication 1660 for a full explanation of the CDP process.
This notice also explains the possible denial or revocation of your United States passport. Visit Revocation or Denial of Passport in Case of Certain Unpaid Taxes for further information.
You have a balance on your tax account which you have not paid, and the IRS has filed a public document, the Notice of Federal Tax Lien, with the local and/or state authorities to alert creditors that the government has a right to your interests in any current and future property and assets.
The first thing to do is to check the return address to be sure it’s from the Internal Revenue Service and not another agency.
If it’s from the IRS, the notice will have instructions on how to respond and provide a specific website link for you to visit for additional information located at the end of the notice or letter. Visit I Got a Notice From the IRS for further details including what to do if the notice is not from the IRS.
Also, if the IRS has already issued a CDP notice for that particular tax debt, then you can still request a hearing with Appeals either before or after the IRS files an NFTL. You will need to request a conference through the Collection Appeals Program (CAP), but unlike a CDP hearing, you may not seek review of Appeal’s determination in the U.S. Tax Court. See Publication 1660 for a full explanation of the CAP.
You can also ask that the IRS manager review your case informally. You can obtain the manager’s name and phone number by contacting the employee listed on your notice. IRS employees are required to give you their manager’s name and phone number.
Once a lien arises, the IRS generally can’t release it until you’ve paid the tax, penalties, interest, and recording fees in full or until the IRS is no longer legally able to collect the tax. However, in certain circumstances a lien may be withdrawn, discharged, or subordinated. Visit Liens for further information.
Even if you can’t pay the taxes you owe, responding to a notice before the due date could prevent a lot of trouble. Be sure to keep your address up to date with the IRS so you receive all notices and letters.
If you can’t pay the full amount you owe, you have payment options to help you settle your debt over time
You may be able to raise your arguments in a CDP hearing, an equivalent hearing or request an audit reconsideration. See also Publication 1660 and Publication 5, Your Appeal Rights and How to Prepare a Protest If You Don’t Agree.
You can hire an attorney, certified public accountant (CPA), or enrolled agent to help you if you wish.
If your income is below a certain level, you may qualify for Low Income Taxpayer Clinic (LITC) representation.
Note: The IRS has several videos that relate to each topic that may be helpful to view in addition to the information shared here.
Understanding your notice or letter
For more specifics on your notice, visit Understanding your IRS Notice or Letter on IRS.gov or Understanding a Federal Tax Lien.
If you still need help
The Taxpayer Advocate Service is an independent organization within the IRS that helps taxpayers and protects taxpayers’ rights. We can offer you help if your tax problem is causing a financial difficulty, you’ve tried and been unable to resolve your issue with the IRS, or you believe an IRS system, process, or procedure just isn’t working as it should. If you qualify for our assistance, which is always free, we will do everything possible to help you.
Visit dev.taxpayeradvocate.irs.gov or call 
1-877-777-4778.
Low Income Taxpayer Clinics (LITCs) are independent from the IRS and TAS. LITCs represent individuals whose income is below a certain level and who need to resolve tax problems with the IRS. LITCs can represent taxpayers in audits, appeals, and tax collection disputes before the IRS and in court. In addition, LITCs can provide information about taxpayer rights and responsibilities in different languages for individuals who speak English as a second language. Services are offered for free or a small fee. For more information or to find an LITC near you, see the LITC page on the TAS website or Publication 4134, Low Income Taxpayer Clinic List.
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Related Notices and Letters
Lien Subordination
