IRS Letter 3172: Notice of Federal Tax Lien Filing and Your Right to a CDP Hearing

A federal tax lien is public record and attaches to your property.

Your deadline

30 days from notice date to request a CDP hearing on the lien

A CDP hearing on a lien filing can result in lien withdrawal, subordination, or discharge — but the 30-day window to request it is strict.

How soon to act: Critical

What this notice means

Letter 3172 gives notice of a federal tax lien filing and a deadline to request a hearing under IRC §6320. Credit bureaus stopped reporting tax liens in 2018, but a lien is public record and attaches to your property.

Letter 3172 informs you that the IRS has filed a Notice of Federal Tax Lien (NFTL) with your county recorder or state authority. This lien is now public record and attaches to all of your property — real estate, financial assets, personal property, and future assets acquired while the lien is active.

Credit bureaus stopped reporting tax liens in 2018, but a lien is public record and attaches to your property. The lien may affect a sale or refinancing and establishes the government's priority over property.

Letter 3172 also gives you one more set of rights: you can request a CDP hearing under IRC §6320 within 30 days. At that hearing, you can challenge the lien, propose collection alternatives, and request lien withdrawal or subordination. Missing this window does not eliminate the lien — it remains until the debt is resolved.

How it works

1
Request a CDP hearing (Form 12153) within 30 days to challenge the lien
2
Explore lien withdrawal if you qualify — a withdrawal removes the lien from public record entirely
3
Explore lien subordination if you need to refinance to pay the IRS

Other options

Explore lien discharge if you need to sell a specific piece of property
Pay the balance in full — lien releases within 30 days of full payment
Establish an installment agreement — Direct Debit agreements can qualify for lien withdrawal in some cases

If you do nothing

Maintain a lien on all current and future property for up to 10 years (plus extensions)
Block the sale or refinancing of your home or business property
Collect from the proceeds of any property sale (real estate, business sale, vehicle)
Prevent you from obtaining business loans, SBA financing, or lines of credit
File additional liens in other counties or states where you hold property
Levy (seize) property separately from the lien if a levy notice has also been issued

Which sounds like you?

Lien & Levy Release

Remove the lien through withdrawal, discharge, or subordination

IRS Appeals & CDP Hearings

Challenge the lien and propose alternatives at a CDP hearing

Offer in Compromise

Settle the underlying debt — lien releases when OIC is accepted and paid

Installment Agreement

Direct Debit IAs may qualify for lien withdrawal under Fresh Start

Common questions

Will a federal tax lien ruin my credit?

Credit bureaus stopped reporting tax liens in 2018, but a lien is public record and attaches to your property. Lenders and title companies may still review the public filing.

What is the difference between lien withdrawal and lien release?

A release means the lien is satisfied — it remains on public record as 'released.' A withdrawal removes the lien entirely from public record, as if it never existed. Withdrawal is the superior outcome.

Can I sell my house with a federal tax lien on it?

Yes, but the IRS must be paid from the proceeds at closing, or you must obtain a lien discharge for the specific property before closing. This requires working with the IRS or a tax professional.

How long does a federal tax lien last?

Ten years from the date of tax assessment, with the possibility of extension through court action or collection statute suspension. The lien releases automatically if the collection statute expires and the IRS does not refile.