IRS notice
IRS Letter 3172: A Federal Tax Lien Was Filed. What Now?
The IRS has filed a public Notice of Federal Tax Lien for unpaid tax and is telling you how to request a hearing.
Act now
The hearing request date in the letter, set by section 6320 as a 30-day window that starts after the IRS's five-business-day notice period, cannot be extended; missing it loses Tax Court review.
This deadline is set by law and cannot be extended.
Letter 3172 tells you the IRS has filed a Notice of Federal Tax Lien for the unpaid balances listed on the enclosed Form 668(Y)(c), and explains your right to a Collection Due Process hearing under Internal Revenue Code section 6320. If you disagree with the filing or want Appeals to consider an alternative, file Form 12153 by the date in the letter; otherwise, pay or arrange the balance so the lien can be released.
What this notice is telling you
- The IRS has already filed the Notice of Federal Tax Lien, so it is now a public record.
- The lien is the government's legal claim against your property; the filed notice tells creditors about it and secures the IRS's priority.
- It generally attaches to property you own now and property you acquire later, while the lien remains in effect.
- The enclosed Form 668(Y)(c) shows the tax type, periods, assessment dates and unpaid balance for each liability.
- If you don't respond, nothing about the lien changes on its own; it stays in place until it is released.
What to do
Read the Form 668(Y)(c) line by line
Check each tax period and balance against your records. Note the hearing deadline printed in the letter.
Get a current payoff amount
The balance on the lien notice grows with interest. Contact the person or number listed on the letter for a current payoff figure before you pay.
Decide whether to request a hearing
If you think the lien was filed in error, want to propose a payment plan or offer, or want to ask Appeals to consider lien withdrawal, file Form 12153 by the deadline in the letter.
Consider a Collection Appeals Program conference too
Form 9423, Collection Appeal Request, asks for a conference with the Independent Office of Appeals about the lien. Publication 1660 compares the two routes.
Plan for the release
Once the balance is paid, or another release condition is met, follow Publication 1450 to request a Certificate of Release of Federal Tax Lien if you need it for a sale or loan.
What the lien does and doesn't do
A lien is not a levy. It does not take money from your account or your paycheck; it secures the IRS's claim. The practical effect is on transactions: the filed notice is a public record, so a buyer, lender or title company can find it, and it can make it harder to sell or refinance property until it is dealt with. Federal tax liens no longer appear on credit reports, but a potential creditor can still find them in public records and take them into account. If the IRS has certified the debt as seriously delinquent, it can also affect your ability to get or keep a US passport.
Why the deadline in the letter is an estimate of a statutory window
Section 6320 requires the IRS to send this notice within five business days after the lien notice is filed, and gives you a 30-day period to request a hearing that begins the day after that five-day period. The letter turns that into a specific date. Use the date printed on your letter and treat it as fixed: a timely request preserves your right to petition the Tax Court after Appeals decides.
| Route | What it means |
|---|---|
| Release after full payment | The IRS releases the lien when the balance is paid in full. |
| Release when collection time runs out | The lien is released when the IRS's time to collect the tax expires. |
| Release after an accepted offer in compromise | The IRS releases the lien when it accepts an offer in compromise. |
| Late hearing request | If you miss the CDP date, you may request an equivalent hearing within one year of the notice date, but generally cannot take Appeals' decision to the Tax Court. |
If you do nothing
The lien stays on public record and continues to attach to new property you acquire until it is released. The lien filing does not stop collection: if the balance remains unpaid, the IRS can still move to levy after giving the required notice of intent to levy and hearing rights.
Where this notice sits
- CP504
- Letter 3172
The usual order. Not every account gets every notice, and some steps can be skipped.
Want a CPA to deal with it?
Bring the notice to a free consultation, in person on James Island or by video. We read it with you, tell you what it means for your account and, if you want us to, take over the response once you sign Form 2848.
IRS & SCDOR letters — Find your notice number below, see what it means and which date matters, then let a licensed CPA deal with the IRS or SCDOR on your behalf.
Sources
By Haigler CPA Group. Updated . Notices are revised from time to time, so go by the wording and dates on your own notice. The information on this site is general in nature and is not tax, legal, or accounting advice for your situation. Tax law changes and the right answer depends on facts we would need to review with you. Please speak with a qualified professional before acting on anything you read here.
Questions about Letter 3172
Is the hearing in Letter 3172 the same as the one in a levy notice?
It uses the same Collection Due Process procedure and the same Form 12153, heard by the Independent Office of Appeals. The difference is the subject: Letter 3172 covers the lien filing under section 6320, while levy notices such as CP90 or LT11 cover a proposed seizure under section 6330. You may receive both, each with its own deadline.
Does a filed tax lien show up on my credit report?
Federal tax liens no longer appear on credit reports. The lien notice is still a public record, though, and a lender or title company can find it and consider it.
Will paying the balance remove the lien right away?
Full payment is one of the conditions for release. To get a Certificate of Release, follow the steps in IRS Publication 1450, and allow time for the release to be recorded.
Can I still challenge the lien if I miss the hearing date?
You may request an equivalent hearing within one year of the notice date using Form 12153, or ask for a Collection Appeals Program conference with Form 9423. After an equivalent hearing, you generally cannot go to the Tax Court.
Other notices
- CP90: Final notice: intent to levy and your right to a hearingFinal notice before the IRS levies wages, bank accounts or other property, with a 30-day window to request a Collection Due Process hearing.
- LT11 / Letter 1058: Final notice of intent to levy and your right to a hearingFinal notice that the IRS plans to seize property for an unpaid balance, with a hearing deadline that cannot be extended.
- CP503: Second reminder: balance still unpaidThe second reminder about an unpaid balance; the IRS still hasn't heard from you and a lien filing is now possible.
- IRS notice lookupEvery IRS notice carries a code. Find yours below to see what it generally means, which date matters, and what to do before that date passes.
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