IRS CDP Lien Hearing (Form 12153)

IRS Notice of Federal Tax Lien — What It Means & What To Do

If the IRS has filed a Notice of Federal Tax Lien (NFTL) against you, it means the government has placed a legal claim against your property due to unpaid tax debt.

A lien does not seize assets.

It does, however:

• Attach to your property

• Appear in public records

• Impact credit

• Affect refinancing or property sales

• Signal escalating IRS collection action

You generally have 30 days from the date of the lien filing notice (Letter 3172) to request a Collection Due Process (CDP) hearing by filing Form 12153.

What Is a CDP Lien Hearing?

A CDP Lien Hearing allows you to formally request review of the IRS lien filing before enforcement continues.

At this stage, you may be able to:

• Challenge procedural validity

• Propose an Installment Agreement

• Submit an Offer in Compromise

• Request lien withdrawal

• Request lien subordination (to refinance)

• Request lien discharge (for property sale)

Timely filing preserves your full appeal rights.

This Is NOT a Levy Notice

This page applies specifically to:

• Notice of Federal Tax Lien (NFTL)

• Letter 3172

It does NOT apply to:

• CP90 / LT11 wage or bank levy notices

• CP297 business levy notices

• CP523 installment default notices

• CP75 refund review notices

Those require different documentation systems.

Your 30-Day Deadline Matters

If you file Form 12153 within 30 days of the lien notice, you preserve full Collection Due Process appeal rights.

Missing the deadline may limit your appeal options.

What This Documentation System Provides

• Step-by-step explanation of lien rights

• Form 12153 completion guidance (lien context)

• Deadline confirmation checklist

• Structured documentation worksheets

• Submission mechanics guide

• Post-filing expectations overview

• Organized tracking workbook

Delivered as structured digital templates for documentation preparation.

Who This System Is For

• Individuals with a federal tax lien filed

• Business owners affected by lien filings

• Property owners needing refinancing or sale clearance

• Taxpayers seeking to challenge or modify lien terms

Frequently Asked Questions

Is a lien the same as a levy?

No. A lien is a legal claim against property. A levy is actual seizure of assets.

How long do I have to respond?

You generally have 30 days from the lien filing notice to request a CDP hearing.

Can a lien be removed?

In certain circumstances, withdrawal, discharge, or subordination may be possible.

Does this include legal representation?

No. This is a documentation system. It does not provide legal or tax advice.