IRS Tax Lien Appealing

The law requires us to notify you in writing not more than 5 business days after the filing of a lien. We may give you this notice in person, leave it at your home or your usual place of business, or send it by certified or registered mail to your last known address. You may ask an IRS manager to review your case, and you may request a Collection Due Process hearing with the Office of Appeals by filing a request for a hearing with the office listed on your notice. You must file your request by the date shown on your notice. Some of the issues you may discuss include:

• You paid all you owed before we filed the lien,
• We assessed the tax and filed the lien when you were in bankruptcy, and subject to the automatic stay during bankruptcy,
• We made a procedural error in an assessment,
• The time to collect the tax (called the statute of limitations) expired before we filed the lien,
• You did not have an opportunity to dispute the assessed liability,
• You wish to discuss the collection options, or
• You wish to make spousal defenses.

At the conclusion of your Collection Due Process hearing, the IRS Office of Appeals will issue a determination. That determination may support the continued existence of the filed federal tax lien or it may determine that the lien should be released or withdrawn. If you disagree with Appeal's determination, there is a 30-day period starting with the date of determination, in which you may request judicial review in a court of proper jurisdiction. Refer to Publication 1660 (PDF), Collection Appeal Rights, for more information.