Federal · Internal Revenue Service

Notice of federal tax lien filed

Letter 3172 · Form 668(Y)

What it is: A notice of federal tax lien has been filed in the public record, which protects the government's priority against other creditors. The letter also gives the right to a collection due process hearing, where collection alternatives and lien withdrawal, release, discharge or subordination can be raised.
The clock it starts: 30 days, running from the fifth business day after the filing, to request a collection due process hearing on Form 12153. A request after that period gets an equivalent hearing without court review.
What a response has to establish: A hearing request that proposes the alternative (installment agreement, offer in compromise, withdrawal under §6323(j), discharge or subordination) and the reasons the lien should not stand as filed.
Authority: IRC §6320
IRC §6321
IRC §6323
IRS Publication 1450
IRS Publication 783

What CitedTax drafts for this notice

A collection due process hearing request with the proposed alternative and the lien relief sought, each with its authority.

One credit. Upload the notice, state the firm's position and the facts, and the draft comes back in about thirty minutes with every claim graded against the cited text.

Notice response Pricing

Other federal notices

CP2000 Proposed changes from information-return matching
CP3219A Statutory notice of deficiency (90-day letter)
CP11 Math-error correction to the return
CP21A Changes made to the return
CP59 No return on file
CP2100 Payee name and TIN mismatch (backup withholding)

For tax professionals. The date printed on the notice controls. CitedTax is a research and drafting tool; the reviewing professional validates every item before reliance.