Tax Liens

Tax Liens

A Federal Tax Lien (FTL) is created by statute and attaches to a taxpayer’s property and rights to property for the amount of the liability Per IRM 5.12.2.2. A tax lien is directly reported on your credit report and can hinder one’s ability to apply for loans or purchase of any future property.  The determination of the filing of a federal tax lien is made within ten days of a taxpayer being notified of the tax debt. The notice of taxpayer contact is generally made with the Letter CP 501 or 504.  Normally, a tax lien is filed with the Final notice of Intent of levy (L-1058) which allows the taxpayer thirty days to appeal the filing of tax lien or future levy action on the account.

Generally, the IRS determines that the current tax debt is owed by the taxpayer and all the necessary procedures have been filed by the IRS to file the federal tax lien. The IRS will not always file a tax lien within the initial 10 day contact but the filing of tax lien is priority before the issuance of the Notice of Levy per IRM 5.12.2.4.1.  The filing of a tax lien is also one of the last resorts for the IRS because the taxpayer has failed to resolve the unpaid debt with the IRS.

Solution/Strategy

In case you have a lien filed against your property, our tax experts will perform the following procedures:

• Ensure that you owe the current tax debt
• Ensure that the IRS made the necessary tax debt
• Contact the IRS and initiate to resolve the unpaid tax debt.
• Advise you when the lien can be removed upon the resolution on your account.
• Attempt to prevent any future tax liens.

Our tax team can also help the taxpayer with the lien subordination. This is a tax lien relief for taxpayers who are trying to sell or refinance their house.  The IRS will generally only grant the lien subordination if it will resolve the collection of unpaid tax debt.