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Received a Notice of Federal Tax Lien? Your Rights to a Hearing

Posted by Brandon Keim | Oct 21, 2022 | 0 Comments

If you've received Letter 3172, Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320 (LTR 3172), you are undoubtedly wondering what this all means. Let's briefly review what the LTR 3172 means and what steps you should take now.  

In the LTR 3172, the IRS informs you that, because you have unpaid taxes, it has filed a notice with local and state authorities to alert creditors that the IRS has placed a lien against your property. The notice is a public document stating that it has a right to take ownership of property and assets you currently own and may own in the future. (A lien establishes the IRS' claim that it can take your property, but there's another step—a levy—the IRS uses to actually take it.)

However, you have 30 days from the date of the letter to request a hearing to challenge the lien. You can request a “Collection Due Process hearing,” an informal proceeding (often held over the phone).

During this hearing, you can present arguments why the IRS is incorrect about the amount due or address if the IRS was insufficient in the steps it took to notify you of the lien and other procedural issues. You can also take that time to work out a payment plan. While a Collection Due Process hearing allows you to contest the reasons for the tax bill, it doesn't automatically stay any collections efforts that the IRS may initiate in the meantime.  

Alternatively, you can opt for the “Collections Appeals Program,” which allows you to contest the lien. This program is often faster than the Due Process hearing; however, you're limited to dispute the collection method rather than the underlying reasons for the taxes owed.

Whether you decide on either, the first thing to know is that it's important to act quickly. You need to give yourself time to work out what will be the best option for you. 

If you have questions about a pending tax lien or other issues relating to unpaid taxes, don't wait. If you need help, call Senior Partner, Tax Controversy Attorney, and former IRS attorney Brandon A. Keim at (602) 200-7399 or contact him online to discuss your options.

About the Author

Brandon Keim

A Certified Tax Law Specialist, CPA, partner at Frazer Ryan Goldberg & Arnold LLP, and former Senior IRS Trial Attorney, Brandon Keim holds an LL.M. in Taxation from Georgetown University Law Center.


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