LETTER 3172: Notice of Federal Tax Lien Filing and Your Rights to a Hearing under IRC 6320

What it is

Notification that the IRS has filed a Notice of Federal Tax Lien (Form 668(Y)) — a public document filed with local or state authorities to alert creditors that the government has a legal claim to your property for an unpaid tax debt. A lien is not a levy: a lien secures the government's interest in your property; a levy actually takes the property. This letter carries a major right with it — 30 days to request a Collection Due Process hearing under IRC §6320 using Form 12153.

Why you got it

Sent because the IRS assessed the tax, sent a notice and demand for payment, the balance went unpaid, and the IRS filed the lien notice. IRC §6320 requires the IRS to notify you in writing — in person, left at your home or business, or by certified or registered mail — not more than 5 business days after the lien filing.

The deadline structure

You have 30 days to request a Collection Due Process hearing with the IRS Independent Office of Appeals: irs.gov says to file Form 12153 and send it to the address shown on your lien notice within 30 days from the date of the letter. The statute defines the window precisely — notice within 5 business days of the lien filing, then a 30-day request period beginning the day after that 5-business-day period ends (IRC §6320(a)). A timely request gets the lien filing reviewed by an impartial Appeals officer and preserves your right to petition the U.S. Tax Court afterward.

The CDP deadline printed on YOUR letter controls. Miss it and you can still request an 'equivalent hearing' within 1 year of the notice date — but you generally lose the right to petition the U.S. Tax Court.

How to respond

• File Form 12153 (Request for a Collection Due Process or Equivalent Hearing) to the address shown on your lien notice — within the 30-day window
• Call the number printed on the letter with questions — but a phone call is not a hearing request; the written Form 12153 is what preserves CDP rights
• Pay the balance in full — the IRS releases the lien within 30 days after the tax debt is paid

What ignoring it leads to

The lien stays attached to everything you own now and property you acquire while it lasts — including business property and rights to business property such as accounts receivable. It may limit your ability to get credit and can continue through bankruptcy. Penalties and interest keep accruing. And a filed lien whose §6320 hearing rights have lapsed is one of the two statutory triggers that can make a large enough debt 'seriously delinquent' for passport certification (CP508C).

Mistakes people make with a LETTER 3172

• Reading 'lien' as 'levy' and assuming property is being seized — nothing is taken by this letter. A lien secures the government's claim; a levy takes property, and levy has its own separate final notice (LT11 / Letter 1058) with its own hearing right
• Calling the IRS but never filing Form 12153 — only the written request within the 30-day window preserves the CDP hearing and the Tax Court path; the later equivalent hearing generally does not
• Confusing release with withdrawal — full payment gets the lien released within 30 days, but withdrawal is what removes the public Notice of Federal Tax Lien itself, and it has its own conditions (the direct-debit installment route requires $25,000 or less owed, three consecutive direct-debit payments, and full payoff within 60 months)
• Overlooking discharge and subordination — discharge removes the lien from a specific piece of property, and subordination lets another creditor move ahead of the government's claim without removing the lien

Official sources

• Letters and notices offering an appeal opportunity
• Understanding a federal tax lien
• Letter 3172 — Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 (Taxpayer Advocate Service)
• 26 U.S.C. § 6320 — Notice and opportunity for hearing upon filing of notice of lien (5-business-day notice; 30-day hearing request window)

Our summary paraphrases these sources. Last verified: BUILD 2026-07-11 (Claude Fable 5; researched from live fetches: irs.gov/appeals/letters-and-notices-offering-an-appeal-opportunity, irs.gov/appeals/collection-due-process-cdp-faqs, irs.gov/businesses/small-businesses-self-employed/understanding-a-federal-tax-lien, taxpayeradvocate.irs.gov/notices/letter-3172, law.cornell.edu/uscode/text/26/6320; note: irs.gov/individuals/understanding-your-letter-3172 returns 404 — no dedicated www.irs.gov page exists) — re-verify before launch. Your printed notice always controls.

NoticeKey is not affiliated with, or endorsed by, the IRS or any state tax agency.