Federal Tax Liens Certificates related to a Notice of ......A. IRC § 6325(b)(1) permits discharge if the remaining property of the taxpayer has a fair market value that is double

Federal Tax Liens Certificates related to a Notice of Federal Tax Lien

Dallas Advisory Group

2010

Ms. Margaret Glasgow Advisory Manager, IRS

1100 Commerce, Mc 5028 DAL Dallas, TX

Phone: 214-413-5348 [email protected]

Margaret Glasgow Internal Revenue Service

Advisory Manager Dallas, TX

Margaret was born a Native Texan and is very proud of that background. She attended high school and college in the Dallas/Ft. Worth Metroplex. She began her IRS career in 1981 and, to enhance her value to the Service, intentionally ensured she had a varied background within Collection functions to ensure she was well versed in all Collection aspects. She initially started as a Revenue Officer in Victoria, Texas and transferred to the Ft. Worth office in 1984. From there she went to the Dallas office as an advisor for revenue officers in 1985. She quickly moved into a management position for the Bankruptcy unit and remained there until 1992 when she moved to a Collection Group Manger of Revenue Officers. Finding her calling as a teacher she moved to the position of Advisory Group Manager in 1998 and has been there ever since. She keeps her Collection skills current by teaching all over the United States in Advanced Technical Classes for Revenue Officers. For several years in a row she has been recognized by her management staff for her exceptional performance and was recently awarded the Public Service Excellence Award by the Federal Executive Board. During her management tenure she was the Loaned Executive to the Combined Federal Campaign in 1997 which resulted in the highest contributions to date.

Certificates related to a Notice of Federal Tax Lien

A federal tax lien (“FTL”) arises when the IRS assesses a tax liability, sends the taxpayer notice and demand for payment, and the taxpayer does not fully pay the debt within ten days1/. A FTL is effective as of the date of assessment and attaches to all of the taxpayer’s property and rights to property, whether real or personal, including those acquired by the taxpayer after that date2/. This lien remains until the liability is either fully paid or is legally unenforceable3/. This statutory lien is sometimes called a “secret” lien, because third parties – and usually the taxpayer – have no knowledge of the existence of this lien or the underlying tax debt. To put third parties on notice and establish the priority of the government’s interest in a taxpayer’s property against subsequent purchasers, secured creditors, and junior lien holders, the IRS must file a Notice of Federal Tax Lien (“NFTL”) in the appropriate location, such as a county registrar of deeds4

/.

A NFTL places other creditors on notice of the existence of a tax delinquency and bolsters the IRS’s claim to an interest in taxpayer’s property as security or payment for their tax debt. A NFTL may be filed only after certain requirements are met5

/. By filing notice of this lien, the taxpayers’ creditors are publicly notified that the IRS has a claim against all of their property, including property they acquire after the lien is filed. This notice is used by courts to establish priority in certain situations, such as bankruptcy proceedings or sales of real estate.

The IRS issued nearly one million NFTL in fiscal year (“FY”) 20096/. This was an increase of 85% from the number of NFTLs filed in FY 2005. During this period the number of Forms 1040 filed with unpaid balances due increased by only 24%7

1 Internal Revenue Code (“IRC”) §§ 6321 and 6322. IRC § 6201 authorizes the IRS to assess unpaid taxes. IRC § 6303 provides that within 60 days of the assessment the IRS must give notice and make demand for payment to any taxpayer liable for an unpaid tax.

/.

2 See IRC § 6321. 3 IRC § 6322. However, as detailed in this presentation and the materials that follow, the IRS may agree to release, subordinate, or discharge specific property from the lien 4 IRC § 6323(f); Treas. Reg. § 301.6323(f)-1; IRM 5.12.2.8 (Oct. 30, 2009). A copy of a NFTL can be found in the accompanying overhead viewer presentation materials. 5 See supra fn 1. The IRS must first assess the liability. The IRS will then send the taxpayer a Notice and Demand for Payment, which is a bill that tells how much is owed in taxes. Next, the taxpayer must neglect or refuse to fully pay the bill (debt) within 10 days after notification. In addition, the IRS exercises its administrative discretion by only filing a lien if the tax debt exceeds a certain dollar threshold. 6 Taxpayer Advocate Service, 2009 Annual Report to Congress, Vol. 2, p. 6.

Certificate of Release IRC § 6325(a) requires the issuance of a release of federal tax lien within 30 days of the date on which:

A. The liability is satisfied, B. The liability becomes legally unenforceable (e.g., expiration of the

statutory period limiting collection or discharge in bankruptcy), or C. A bond is accepted.

Publication 1450, Request for Release of Federal Tax Lien, explains when a Certificate of Release of Federal Tax Lien (IRS Form 668(Z)) may be issued and the required content of the request.

Partial Lien Release

There is no provision in the Internal Revenue Code or the Regulations specifically providing for the issuance of a partial release. A partial release of the NFTL may, nevertheless, be obtained to release one taxpayer from a joint tax liability where, e.g., one jointly liable taxpayer is relieved from the liability by a discharge, through an innocent spouse determination or through an offer-in-compromise. Additionally, a partial release may be obtained where the liability of a specific period, but not all periods, listed in a NFTL has been satisfied.

However, a partial release is not the proper procedure to pursue when a sale of real estate encumbered by a NFTL is proposed but the requirements for a Certificate of Release cannot be met. In such a case, a real estate transaction can still go forward by obtaining a discharge the specific property from the NFTL.

Certificate of Discharge

Specific real or personal property may be discharged from a FTL without disturbing the NFTL with respect to all other property to which it has attached.

7 Id.

A. IRC § 6325(b)(1) permits discharge if the remaining property of the taxpayer has a fair market value that is double the sum of the amount of the FTL and other liens that have a priority over the FTL. The IRS will issue Form 669–A, Certificate of Discharge of Property from Federal Tax Lien Under Sec. 6325(b)(1) of the Internal Revenue Code.

B. IRC § 6325(b)(2)(A) permits discharge after partial satisfaction of the liability in an amount equal to the value of the government’s interest in the property. The IRS will issue Letter 403, Conditional Commitment, and Form 669–B, Certificate of Discharge of Property From Federal Tax Lien Under Sec. 6325(b)(2)(A) of the Internal Revenue Code.

C. IRC § 6325(b)(2)(B) permits discharge if it is determined that the interest of the United States in the property to be discharged from the lien has no value. The IRS will issue Letter 402, Conditional Commitment, and Form 669–C, Certificate of Discharge of Property From Federal Tax Lien Under Sec. 6325(b)(2)(B) of the Internal Revenue Code.

D. IRC § 6325(b)(3) permits discharge if the proceeds of the sale are held as a fund subject to the liens and claims of the government in the same manner and priority as was the property that was discharged. The IRS will issue Form 669-H, Certificate of Discharge of Property from Federal Tax Lien Under Sec. 6325(b)(3) of Internal Revenue Code.

E. IRC § 6325(b)(4) requires discharge after the third party owner, not the taxpayer, deposits the value of the government’s interest in the property in cash or provides an acceptable bond. In connection with an application for discharge of former entireties property, under this provision the Service will generally determine the value of the government’s interest to be one-half the value of the property. The IRS will issue Form 669-G, Certificate of Discharge of Property from Federal Tax Lien Sec. 6325(b)(4) of the Internal Revenue Code.

Other Certificates Relating to NFTLs

A. Subordination - elevates another creditor’s lien to the Service’s priority position making the Service’s lien junior to that creditor’s lien. IRC § 6325(d).

B. Nonattachment - denotes that a person of like or similar name is not, in fact, the taxpayer. IRC § 6325(e).

C. Revocation - reinstates the statutory lien when a NFTL is released or allowed to lapse in error. IRC § 6325(f)(2).

D. Withdrawal - removes the NFTL from public records abandoning the priority under IRC § 6323(a) but does not disturb the statutory tax lien against the taxpayer under IRC § 6321.

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§ 6325. Release of lien or discharge of property

(a) Release of lien

Subject to such regulations as the Secretary may prescribe, the Secretary shall issue a certificate of release of any lien imposed with respect to any internal revenue tax not later than 30 days after the day on which— (1) Liability satisfied or unenforceable The Secretary finds that the liability for the amount assessed, together with all interest in respect thereof, has been fully satisfied or has become legally unenforceable; or (2) Bond accepted There is furnished to the Secretary and accepted by him a bond that is conditioned upon the payment of the amount assessed, together with all interest in respect thereof, within the time prescribed by law (including any extension of such time), and that is in accordance with such requirements relating to terms, conditions, and form of the bond and sureties thereon, as may be specified by such regulations. (b) Discharge of property (1) Property double the amount of the liability Subject to such regulations as the Secretary may prescribe, the Secretary may issue a certificate of discharge of any part of the property subject to any lien imposed under this chapter if the Secretary finds that the fair market value of that part of such property remaining subject to the lien is at least double the amount of the unsatisfied liability secured by such lien and the amount of all other liens upon such property which have priority over such lien.

(2) Part payment; interest of United States valueless Subject to such regulations as the Secretary may prescribe, the Secretary may issue a certificate of discharge of any part of the property subject to the lien if— (A) there is paid over to the Secretary in partial satisfaction of the liability secured by the lien an amount determined by the Secretary, which shall not be less than the value, as determined by the Secretary, of the interest of the United States in the part to be so discharged, or (B) the Secretary determines at any time that the interest of the United States in the part to be so discharged has no value. In determining the value of the interest of the United States in the part to be so discharged, the Secretary shall give consideration to the value of such part and to such liens thereon as have priority over the lien of the United States. (3) Substitution of proceeds of sale Subject to such regulations as the Secretary may prescribe, the Secretary may issue a certificate of discharge of any part of the property subject to the lien if such part of the property is sold and, pursuant to an agreement with the Secretary, the proceeds of such sale are to be held, as a fund subject to the liens and claims of the United States, in the same manner and with the same priority as such liens and claims had with respect to the discharged property. (4) Right of substitution of value (A) In general At the request of the owner of any property subject to any lien imposed by this chapter, the Secretary shall issue a certificate of discharge of such property if such owner— (i) deposits with the Secretary an amount of money equal to the value of the interest of the United States (as determined by the Secretary) in the property; or (ii) furnishes a bond acceptable to the Secretary in a like amount. (B) Refund of deposit with interest and release of bond The Secretary shall refund the amount so deposited (and shall pay interest at the overpayment rate under section 6621), and shall release such bond, to the extent that the Secretary determines that— (i) the unsatisfied liability giving rise to the lien can be satisfied from a source other than such property; or (ii) the value of the interest of the United States in the property is less than the Secretary’s prior determination of such value. (C) Use of deposit, etc., if action to contest lien not filed If no action is filed under section 7426 (a)(4) within the period prescribed therefor, the Secretary shall, within 60 days after the expiration of such period—

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(i) apply the amount deposited, or collect on such bond, to the extent necessary to satisfy the unsatisfied liability secured by the lien; and (ii) refund (with interest as described in subparagraph (B)) any portion of the amount deposited which is not used to satisfy such liability. (D) Exception Subparagraph (A) shall not apply if the owner of the property is the person whose unsatisfied liability gave rise to the lien. (c) Estate or gift tax Subject to such regulations as the Secretary may prescribe, the Secretary may issue a certificate of discharge of any or all of the property subject to any lien imposed by section 6324 if the Secretary finds that the liability secured by such lien has been fully satisfied or provided for. (d) Subordination of lien Subject to such regulations as the Secretary may prescribe, the Secretary may issue a certificate of subordination of any lien imposed by this chapter upon any part of the property subject to such lien if— (1) there is paid over to the Secretary an amount equal to the amount of the lien or interest to which the certificate subordinates the lien of the United States, (2) the Secretary believes that the amount realizable by the United States from the property to which the certificate relates, or from any other property subject to the lien, will ultimately be increased by reason of the issuance of such certificate and that the ultimate collection of the tax liability will be facilitated by such subordination, or (3) in the case of any lien imposed by section 6324B, if the Secretary determines that the United States will be adequately secured after such subordination. (e) Nonattachment of lien If the Secretary determines that, because of confusion of names or otherwise, any person (other than the person against whom the tax was assessed) is or may be injured by the appearance that a notice of lien filed under section 6323 refers to such person, the Secretary may issue a certificate that the lien does not attach to the property of such person. (f) Effect of certificate (1) Conclusiveness Except as provided in paragraphs (2) and (3), if a certificate is issued pursuant to this section by the Secretary and is filed in the same office as the notice of lien to which it relates (if such notice of lien has been filed) such certificate shall have the following effect: (A) in the case of a certificate of release, such certificate shall be conclusive that the lien referred to in such certificate is extinguished;


http://www.law.cornell.edu/uscode/html/uscode26/usc_sec_26_00006324---B000-.html�


(B) in the case of a certificate of discharge, such certificate shall be conclusive that the property covered by such certificate is discharged from the lien; (C) in the case of a certificate of subordination, such certificate shall be conclusive that the lien or interest to which the lien of the United States is subordinated is superior to the lien of the United States; and (D) in the case of a certificate of nonattachment, such certificate shall be conclusive that the lien of the United States does not attach to the property of the person referred to in such certificate. (2) Revocation of certificate of release or nonattachment If the Secretary determines that a certificate of release or nonattachment of a lien imposed by section 6321 was issued erroneously or improvidently, or if a certificate of release of such lien was issued pursuant to a collateral agreement entered into in connection with a compromise under section 7122 which has been breached, and if the period of limitation on collection after assessment has not expired, the Secretary may revoke such certificate and reinstate the lien— (A) by mailing notice of such revocation to the person against whom the tax was assessed at his last known address, and (B) by filing notice of such revocation in the same office in which the notice of lien to which it relates was filed (if such notice of lien had been filed). Such reinstated lien (i) shall be effective on the date notice of revocation is mailed to the taxpayer in accordance with the provisions of subparagraph (A), but not earlier than the date on which any required filing of notice of revocation is filed in accordance with the provisions of subparagraph (B), and (ii) shall have the same force and effect (as of such date), until the expiration of the period of limitation on collection after assessment, as a lien imposed by section 6321 (relating to lien for taxes). (3) Certificates void under certain conditions Notwithstanding any other provision of this subtitle, any lien imposed by this c hapter shall attach to any property with respect to which a certificate of discharge has been issued if the person liable for the tax reacquires such property after such certificate has been issued. (g) Filing of certificates and notices If a certificate or notice issued pursuant to this section may not be filed in the office designated by State law in which the notice of lien imposed by section 6321 is filed, such certificate or notice shall be effective if filed in the office of the clerk of the United States district court for the judicial district in which such office is situated. (h) Cross reference For provisions relating to bonds, see chapter 73 (sec. 7101 and following).






Federal Tax Liens

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Federal Tax Liens

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Federal Tax Liens

IRC 6321Statutory Lien.

Attaches to a taxpayer’s property and rights to property in existence.Attaches to future property coming into existence at a later date.Silent/assessment lien/10 year statute

Federal Tax Liens

IRC 6323Notice of Federal Tax Lien

Establishes government’s priority over other creditors.Federal law decides priority/State law decides ownership.First in Time > First in Line

Federal Tax Liens

Protected Interest:Real Property tax/special assessments

Ad ValoremUtility liensMowing liensHOA

Certain Mechanic’s LiensConstruction or improvementLimited to $6,890.00 (2010)

Federal Tax Liens

Unprotected Interest:State Tax LiensLandlord LiensBusiness Personal Property taxesABJ’s do not attach to homesteadPersons receiving property in a:

DivorceHeirs/gifts/donations/Trust

Federal Tax Liens

What is the most important

thing you do as a

Title Company?

Federal Tax Liens

It’s, okay. The IRS

is just protecting

the Government’s

interest!

Federal Tax Liens

Full payment of all the periods shown on a NFTLis required.

To Obtain a Release of Notice of Federal Tax Lien?

Please Do Not

Send Cash

Federal Tax Liens

Lien Payoff/Release Request:Lien ProcessingInternal Revenue ServiceP.O. Box 145595Mail Stop 8420 GCincinnati, Ohio 45250Ph# 800-913-6050Fax#859-669-3805

(or contact assigned Revenue Officer)

Payoff Letter Request

Request for Lien Payoff must includethe following:

Request must include taxpayers name and identification number/lien serial number.Date pay-off should be calculated through.Taxpayer authorization to release information (form 8821 or 2848)Name, phone number and address where requestor may be contacted

Federal Tax Liens

Self-Release Feature on a Notice of Federal Tax Lien?

Form 668(Y) (Rev. 10-1999)

Department of the Treasury - Internal Revenue Service

Notice of Federal Tax Lien

Serial Number For Optional Use by Recording Office

As provided by sections 6321, 6322, and 6323 of the Internal Revenue Code, we are giving a notice that taxes (including interest and penalties) have been assessed against the following-named taxpayer. We have made a demand for payment of this liability, but it remains unpaid. Therefore, there is a lien in favor of the United States on all property and rights to property belonging to this taxpayer for the amount of these taxes, and additional penalties, interest, and costs that may accrue. Name of Taxpayer Residence IMPORTANT RELEASE INFORMATION: For each assessment listed below, unless notice of lien is refiled by the date given in column (e), this notice shall, on the day following such date, operate as a certificate of release as defined in IRC 6325(a).

Kind of Tax (a)

Tax Period Ended (b)

Identifying Number (c)

Date of Assessment

(d)

Last Day for Refiling

(e)

Unpaid Balance of Assessment

(f)

Place of Filing

Total

This notice was prepared and signed at , on this, the day of , . Signature , Employee # -

Title , Phone # -

(NOTE: Certificate of officer authorized by law to take acknowledgements is not essential to the validity of Notice of Federal Tax lien Rev. Rul. 71-466, 1971-2 C.B. 409) Part 1 – Recording Office Form 668(Y) (Rev. 10-1999)

IMPORTANT RELEASE INFORMATION: For each assessment listed below, unless notice of lien is refiled by the date given in column (e), this notice shall, on the day following such date, operate as a certificate of release as defined in IRC 6325(a).


PUB 783

IRC 6325(b)

Divested of

all Rights

and title....


Removes a specific piece of property from the Federal Tax Lien.

Real or Personal Property


IRC 6325(b)(1) > double liability+other senior

IRC 6325(b)(2a) > not less than lien interest

IRC 6325(b)(2b) > lien interest has no value

IRC 6325 (b)(3) > $ held in escrow subject to

IRC 6325 (b)(4) > Bond equal to lien interest


Prepare application (F14135) as per Publication 783

Attachments to application (shown on F14135 and local laundry list).

SeeHandout


Allowable Hud1 Closing CostIndustry standard with the following exceptions:

Attorney fees not related to the closing & excess attorney fees.Option feeSeller paid buyer’s closing costRealtor fee over 6%


Commitment Letter IssuedAmount of lien interestTitle Company to Provideafter closing:

Cashier checkExecuted Hud1Executed Warranty Deed


Short SalesAdditional Attachments to

application:Current short sale agreement.

Current payoff statement by same lender.


Home Equity Line of CreditAdditional Attachments to

application:Disbursement schedule.Current payoff statement only for disbursements made prior to NFTL.

PMM & PMSI

Revenue Ruling 68-57: It is the position of the IRS that a PMM or a PMSI given in “good faith” to secure a loan for the purchase of real property or goods, has priority over an already recorded Notice of Federal Tax Lien

Purchase Money Mortgages

A loan made to purchase real property.

The lender may obtain a Purchase

Money Mortgage (PMM)

IRS Publication 785

PMM & PMSI

Revenue Ruling 68-57:

It is the position of the IRS that a PMM or a PMSI given in good faith to secure a loan for the purchase of real property or goods,has priority over an already recorded Notice of Notice of Federal Tax Lien

Loan

Modification

???

Purchase Money Security Interest

A loan made to purchase personalproperty.

The lender may obtain a PurchaseMoney Security Interest (PMSI)

IRS Publication 785

Certificate of Subordination

PUB 784

IRC 6325(d)


Allows a creditor to move

their junior position ahead of the

United States.


Prepare application (F14134) as per Publication 784.

Attachments needed.

SeeHandout


Allowable Closing Cost

Industry standard with the following exceptions:

Excessive cost of obtaining new loan


Certificate of Nonattachment

That sure ain’t me

on that tax lien!

Publication 1024


Prepare memo/letter per Publication 1024 instructions and include:

Copies of documents that will prove identity of applicant (driver license, social security card, current utility bill).

Copy of NFTL in question.

Just a few more things....

Collection Advisory Group Addresses

Publication 4235:

Provides a list of certificates related to a Notice of Federal Tax Lien and

Provides the addresses for IRS Advisory Group by locations serviced.

Contact Information for North Texas

Call or write to:Advisory UnitMargaret Glasgow, ManagerOffice Telephone No. 214-413-5349Address: Internal Revenue Service

1100 Commerce Street MC 5028DALDallas, TX 75242


Instructions on how to apply for Certificate of Discharge From Federal Tax LienA Certificate of Discharge under Internal Revenue Code Sec-tion 6325(b) removes the United States’ lien from the propertynamed in the certificate. Discharge of property under InternalRevenue Code Section 6325(c) subject to an Estate Tax Lien is not covered in this publication. For Estate Tax Lien discharges see instead the application and instructions found in Form 4422

1. Complete Form 14135, Application for Certificate of Dis-charge of Federal Tax Lien attached with this publication.

2. Mail the completed Form 14135 and the appropriateattachments to: IRS, Attn: Advisory Group Manager(Refer to Publication 4235 Collection Advisory Group Addresses for the correct address. The correct address is the office assigned to the location where the property islocated.)

If you have any questions, contact the applicable Advisory Office.

If you want to know how much you owe in order to pay thelien(s) in full, call 1-800-913-6050, visit the nearest Taxpayer Assistance Center, or contact the revenue officer assigned to your case.

Important!Please submit your application at least 45 days before the trans-action date that the certificate of discharge is needed. Doingso will allow sufficient time for review, determination, notification and the furnishing of any applicable documents by the transac-tion date.

Information Required on the Application Section 1 - Taxpayer Information 1. Enter the name and address of the individual(s) or business

as it appears on the Notice of Federal Tax Lien (NFTL). Asecond name line is provided if needed.

2. Enter, if known, the last 4 digits of the social security number (SSN) or full employer identification number as itappears on the NFTL.

3. Enter, if known and if applicable, the last 4 digits of any spousal SSN (secondary SSN) associated with the tax debtlisted on the NFTL.

4. Provide a daytime phone number and a fax number.

Section 2 - Applicant Information 1. Check the box on the first line of Section 2 if you are both

the taxpayer and the applicant. If you are not the taxpayer, attach a copy of the lien.

2. If you have checked the box indicating that you are the taxpayer and your information is the same as listed on thelien, enter “same as taxpayer” on the name line.

3. If you are not the taxpayer or you are the taxpayer but yourinformation is no longer the same as the information on theNotice of Federal Tax Lien, enter your name (include any name changes), current address, daytime phone numberand fax number.

4. If you are not the taxpayer, enter in the box next to “Name” your relationship to the taxpayer (e.g. parent, uncle, sister, no relation, etc).

Section 3 - Purchaser/Transferee/New Owner 1. Check the box on the first line of Section 3 if you are both

the property owner and the applicant. 2. Enter the name of the property owner. Or enter “NA” if you

have checked the box indicating you are both the applicantand the property owner, enter, “same as applicant”.

3. Enter the property owner’s relationship to the taxpayer (e.g.taxpayer, parent, no relation, etc.).

Section 4 - Attorney/Representative Information This section is used to list the taxpayer’s representative or arepresentative of a party other than the taxpayer, such as the lender, needing to receive information from the IRS. However, you do not need a representative to request discharge of thefederal tax lien. 1. Check the box on the first line of Section 4 if you are attach-

ing a Form 8821 (Tax Information Authority) or Form 2848 (Power of Attorney) with your application. If you are attach-ing one of these forms, please make sure it is completelyfilled out, signed, and dated. You must provide one of these forms if the representative represents an interest other thanthe taxpayer.

2. Enter the name, address, phone number, and fax number of your representative in this action. The IRS will work with you and your representative to process your applica-tion. Or enter “NA” on the name line if you are not using arepresentative.

3. Enter whose interest the representative represents (e.g.taxpayer, lender, title company, etc.). This allows the IRS to determine what information can be shared with the repre-sentative.

Section 5 – Lender/Finance Company Information(Settlement/Escrow Company for Section 6325(b)(3) only)

Enter the company name, contact name, and phone number forthe title or escrow company that will be used at settlement.

Section 6 – Monetary Information 1. Provide the proposed property sale amount 2. Provide the amount of proceeds the IRS can expect for ap-

plication to the tax liability. 3. Enter NA for the amount of proceeds the IRS can expect, if

you anticipate there will be no proceeds.

Section 7 - Basis for Discharge Discharge of property from the federal tax lien may be grantedunder several Internal Revenue Code (IRC) provisions. After reviewing the discharge sections, explanations, and examplesbelow, select the discharge section that best applies to your ap-plication. If the IRS does not agree with your selection after itsreview, an explanation of the decision will be provided.

Publication 783 (Rev. 6-2010) Catalog Number 46755I Department of the Treasury Internal Revenue Services www.irs.gov

http://www.irs.gov/pub/irs-pdf/f4422.pdf

http://www.irs.gov/pub/irs-pdf/p4235.pdf


1. 6325(b)(1) – a discharge may be issued under this pro-vision if the value of the taxpayer’s remaining propertyencumbered by the federal tax lien is equal to at least twicethe amount of the federal tax liability secured by the lienand any encumbrance entered into before the IRS filed itspublic notice of the lien. If there are mortgages, state and/or local taxes, mechanics liens, etc., the amount of these debts would be added to the amount of the tax liability andmultiplied by 2.ExampleTax liability $15,500 Other Debts + 23,334

38,834 X 2

$77,668 The property remaining subject to the lien must be at least$77,668.

2. 6325(b)(2)(A) – a discharge may be issued under thisprovision when the tax liability is partially satisfied with anamount paid that is not less than the value of the UnitedStates’ interest in the property being discharged. For exam-ple, the IRS has a lien totaling $203,000 and with the ... • Property selling for: $215,000 • Minus encumbrances senior to IRS lien: $135,000 • Minus proposed settlement costs: $ 15,000 • The IRS lien interest equals: $ 65,000 After the IRS receives and applies the $65,000 in partialsatisfaction of the tax liability, there remains an outstanding tax debt of $138,000. In the case of Tenancy by Entireties property, the United States is generally paid one-half of the proceeds in partialsatisfaction of the liability secured by the tax lien.

3. 6325(b)(2)(B) - a discharge may be issued under thisprovision when it is determined that the government’sinterest in the property has no value. The debts senior to the federal tax lien are greater than the fair market value ofthe property or greater than the sale value of the property. Submit a copy of the proposed escrow agreement as partof the application.

4. 6325(b)(3) – a discharge may be issued under this provi-sion if an agreement is reached with the IRS allowing theproperty to be sold. Per an escrow agreement the saleproceeds must be held in a fund subject to the claims of theUnited States in the same manner and priority the claimshad prior to the property being discharged. For example, there are two mortgages senior to the IRS tax lien total-ing $32,000 and $5,000. The government’s interest in theproperty is $40,000 and there are liens on the propertyjunior to the IRS lien in the amount of $3,000, $12,000 and$2,990. The proceeds from the sale would be dispensed bypaying the debts in the following sequence. a. $32,000 b. $5,000 c. $40,000 d. $3,000 e. 12,000 f. $2,990

Submit a copy of the proposed escrow agreement.

5. 6325(b)(4) – a discharge will be issued under this provisionto a third party who owns the property if a deposit is madeor an acceptable bond provided equal to the government’sinterest in the property. In the case of Tenancy by

Entireties property, a deposit or an acceptable bondtotaling one-half the government’s interest in the propertymust be made. If you are the property owner (but not thetaxpayer, i.e., you are not responsible for the tax liability) and you make a deposit or post an acceptable bond toobtain a discharge under this section, you have 120 daysto file an action in federal district court, under section 7426(a)(4), challenging the IRS’ determination of thegovernment’s lien interest. This is the exclusive remedyavailable to the third party for the return of the depositor accepted bond or a portion thereof. An administrative request for refund and a refund suit in district court is notavailable. The Circular 570, available at http://fms.treas.gov/c570/index.html contains a list of companies certifiedby the Secretary of the Treasury as providers of acceptable securities.

6. 6325(c) – a discharge of property subject to an Estate Tax Lien is not covered in this publication. Please refer to Form 4422.

Section 8 - Description of Property 1. Enter a detailed description of the property to be discharged

from the federal tax lien. 2. When the property is real estate include the type of prop-

erty, for example, 3-bedroom house; etc. When the property is personal property include serial or vehicle numbers, asappropriate, for example, 2002 Cessna twin engine air-plane, serial number AT919000000000X00; etc.

3. Provide the physical address if real estate or physical loca-tion address if personal property.

4. Check the appropriate box to indicate whether you attacheda copy of the title or deed to the property.

5. If you are applying under 6325(b)(1) check the “Attached”box and attach copies of the titles or deeds for propertyremaining subject to the lien. If you are not applying under6325(b)(1) check the “NA” box.

Section 9 - Appraisal and Valuations 1. Check the “Attached” box after “Required Appraisal” indi-

cate whether you have attached the required appraisal bya disinterested third party. This is typically a professional appraisal providing neighborhood analysis; description ofthe site; description of the improvements; cost approach;comparable sales; definition of market value; certification;contingent and limiting conditions; interior and exteriorphotos of the property; exterior photos of comparable salesused; comparable sales location map; sketch of subjectproperty showing room layout; flood map and qualificationsof the appraiser.

2. Check the appropriate box under the “Plus One of the Fol-lowing Additional Valuations” section to indicate which other type of property value verification is attached with yourapplication. Note: For applications under IRC 6325(b)(1), valuation information described above must also be provided forproperty remaining subject to lien. Note: For property being sold at public auction, providethe date and place of the sale, the proposed amount forwhich the property will be sold, and a statement that theUnited States will be paid in the proper priority from theproceeds.


http://fms.treas.gov/c570/index.html

http://fms.treas.gov/c570/index.html



Section 10 - Federal Tax Liens This section is important when the applicant and the taxpayerare different. If the applicant and the taxpayer are the same,this section may be skipped. 1. Check the “attached” box if you have attached copies of the

liens with your application. 2. If you checked the “no” box list the System Lien Identifica-

tion Number (SLID) found in the top right hand box of thelien document, if available. If you do not have the number(s) enter “unknown” in the first box.

Section 11 - Sales Contract/Purchase Agreement 1. Check the box indicating whether the proposed sales con-

tract or purchase agreement is attached. 2. If you checked the “no” box, describe how the taxpayer

named on the lien will be divested of their interest in the property or why they have no interest in the property.

Section 12 - Title Report 1. Check the box indicating whether the title report is attached. 2. If you checked the “no” box, use the space provided to list

any encumbrances (liens or claims) against the propertythat came into existence before the United States’ lien inter-est or which have priority over the lien. Include name andaddress of holder; description of encumbrance, e.g., mort-gage, state lien, etc.; date of agreement; original amountand interest rate; amount due at time of application; andfamily relationship of the holder, if applicable.

3. Attach a separate sheet with the information in item # 2above if there is not enough space provided on the form.

Section 13 - Closing Statement 1. Check the box indicating whether the proposed closing

statement is attached. This statement is often referred to as a HUD-1.

2. If you checked the “no” box, use the space provided toitemize all proposed costs, commissions, and expenses ofany transfer or sale associated with property.

3. Attach a separate sheet with the information in item # 2above if there is not enough space provided on the form.

Section 14 - Additional Information 1. Check the box indicating whether you are attaching other

documents relevant to the discharge application. This could include affidavits or court documents.

2. Check the “no” box if you do not have any additional docu-mentation.

Section 15 - Escrow Agreement 1. Check the box indicating whether you are attaching a draft

escrow agreement. This is only applicable if you are apply-ing under 6325(b)(3).

2. An escrow agreement must specify type of account,name and depositary for account, conditions under whichpayment will be made, cost of escrow, and the name and address of any party identified as part of the escrow agreement.

Section 16 - Waiver

This section applies only if you are: • The property owner, but • Not liable for the tax debt (i.e. not named on the lien), and • Applying under 6325(b)(2)(A).By checking the “Waive” box you are waiving the option to have the payment treated as a deposit under section 6325(b)(4)which has the accompanying right to request a return of fundsand to bring an action under section 7426(a)(4). If you check the “no” box, your application will automatically beconsidered under 6325(b)(4) which provides for return of depos-ited funds and a court challenge under 7426(b)(4).

Section 17 - Declaration The applicant or their authorized Power of Attorney signs the application form. You must sign your application under penalties of perjury attesting to having examined the application, accom-panying schedules or documents, exhibits, affidavits, and state-ments and declaring to the best of your knowledge and beliefthat it is true, correct and complete.

Frequently Asked Questions Q1: When do I make a payment? The Internal Revenue Code section under which the certificate of discharge will be issued or granted determines the detailsregarding making a payment. • Discharge under 6325(b)(1) or 6325(b)(2)(B) does not require a payment.

• Discharge under 6325(b)(2)(A) requires a payment, but donot send a payment with the application. The Advisory Group Manager will notify you, after determining the amount due,when to send payment.

NOTE: If a mortgage foreclosure is anticipated, the applica-tion is made under section 6325(b)(2)(A) or 6325(b)(2)(B). A determination will be made that either an amount is required fordischarge or the United States’ interest is valueless.

In the case of foreclosure you will receive, within 30 days of thereceipt of a complete and approved application, a conditionalcommitment letter for a certificate of discharge.

NOTE: Relocation Expenses - If a discharge under 6325(b)(2)(A) or 6325(b)(2)(B) is issued and if the sale is of the principalresidence, the taxpayer may be eligible for a relocation expenseallowance because of an inability to pay. The relocation ex-pense allowance is subject to limitations. To apply for the allow-ance complete and submit Form 12451, “Request for RelocationExpense Allowance” with the application for discharge. • Discharge under 6325(b)(3) requires a payment, but do notsend a payment with the application. First, the draft escrowagreement must be submitted. Second, the Advisory Group Manager approves the escrow agent selected by the applicant; any reasonable expensessubmitted as incurred in connection with the sale of the prop-erty; the claim amounts and priorities, and the distributiontiming of the fund.

Third, the agreement is finalized and contains signatures ofall parties involved including Advisory Group Manager prior to the discharge being issued.



Note: The escrow account must be funded before payment of any claim or lien through money paid by the applicant or fromthe sale proceeds.

• Discharge under 6325(b)(4) requires a bond or deposit butdo not send one with the application. The Advisory Group manager must first determine the amount of bond or depositneeded for the discharge and determine that the bond com-pany, if applicable, is from the approved list.

Q2: What is an acceptable form of payment? Make payments in cash or by the following types of checks: cer-tified; cashiers; or treasurer’s check. The check must be drawn on any bank or trust company incorporated under the laws ofthe United States, or of any state, or possession of the UnitedStates. Payment can also be made using a United Statespostal, bank, express or telegraph money order.

Important! If you pay by personal check, issuance of thecertificate of discharge will be delayed until the bank honors thecheck.

Q3: Who makes the decision to issue a Certificate of Discharge? In all cases Advisory staff will review and verify the information provided, determine whether a certificate of discharge shouldbe issued, and contact you with any questions. Advisory maycontact you, your representative, or any person relative to thetransaction for additional information.

The Advisory Group Manager has the responsibility to review and approve the determination and let you know the outcome.If approved, you will receive a conditional commitment letter.

Q4: When will I receive the Certificate of Discharge? The Internal Revenue Code under which the certificate of dis-charge will be issued or granted and the time at which you aredivested of your interest in the property determines when youwill receive the certificate. • Under 6325(b)(1) you will receive the certificate when it isdetermined the remaining property meets the criteria of theprovision.

• Under 6325(b)(2)(A) you will receive the certificate after IRSreceives payment of the agreed upon amount in partial sat-isfaction of the tax liability, proof that the taxpayer has been divested of title, and receipt of a copy of the final settlement statement.

• Under 6325(b)(2)(B) you will receive the certificate when itis determined that the government’s interest in the propertyis valueless, the IRS has received proof that the taxpayerhas been divested of title, and a copy of the final settlement statement.

NOTE: Under provisions 6325(b)(2)(A) and 6325(b)(2)(B)at the conclusion of a mortgage foreclosure the certificatewill be issued in accordance with the terms of the conditional

commitment letter. Also see, Publication 487, How to Preparean Application Requesting the United States to Release Its Right to Redeem Property Secured by a Federal Tax Lien. • Under 6325(b)(3) you will receive the certificate when theamount of the government’s interest in the property has beenplaced in the approved escrow account.

• Under 6325(b)(4) you will receive the certificate when theamount equal to the government’s interest in the property isreceived or an approved bond has posted.

Q5: What happens if my application is denied? If your application is denied, you will receive Form 9423, Col-lection Appeal Request and Publication 1660, Collection Appeal Rights, with an explanation of why your application was denied.

Privacy and Paperwork Reduction Act Notice The Privacy act of 1974 says that when we ask you for informa-tion about yourself, we must first tell you our legal right to askfor the information, why we are asking for it, and how it will beused. We must also tell you what could happen if you do not provide it and whether or not you must respond under the law.

We ask for the information on this form to carry out the Internal Revenue laws of the United States. This information requestedon this form is needed to process your application and todetermine whether the federal tax lien can be discharged. You are not required to apply for discharge; however, if you want the federal tax lien to be discharged, you are required to providethe information requested on this form. Section 6109 requiresyou to provide the requested identification numbers. Failure to provide this information may delay or prevent processing yourapplication; providing any false information may subject you topenalties.

The time needed to complete and file this form will vary de-pending on individual circumstances. The estimated burden for individuals filing this form is approved under OMB controlnumber 1545-2174. The estimated burden for those who file this form is shown below. • Recordkeeping 2 hr., 45 min. • Learning about the law or the form 2 hr. • Preparing the form 1 hr., 30 min. • Copying, assembling, and sending the form to the IRS 85min.

Routine uses of this information include giving it to the Depart-ment of Justice for civil and criminal litigation, and to cities,states, the District of Columbia, and United States common-wealths and possessions for use in administering their tax laws.Advisory may contact you, your representative, or any personrelative to the transaction for additional information. We may also disclose this information to other countries under a tax treaty, to federal and state agencies to enforce federal nontax criminal laws, or to federal law enforcement and intelligenceagencies to combat terrorism.










Form 14135 (June 2010)

Application for Certificate of Discharge ofProperty from Federal Tax Lien

Department of the Treasury — Internal Revenue Service

OMB No. 1545-2174

Complete the entire application. Enter NA (not applicable), when appropriate. Attachments and exhibits should be included as necessary. Additional information may be requested of you or a third party to clarify the details of the transaction(s).

1. Taxpayer Information (Individual or Business named on the notice of lien):

Name (Individual First, Middle Initial, Last) or (Business) as it appears on lien

Name Continuation (Individual First, Middle Initial, Last) or (Business d/b/a)

Address (Number, Street, P.O. Box)

Primary Social Security Number (last 4 digits only)

Secondary Social Security Number (last 4 digits only)

Employer Identification Number

City State ZIP Code

Telephone Number (with area code) Fax Number (with area code)

2. Applicant Information: Check if also the Taxpayer (If not the taxpayer, attach copy of lien. See Sec.10)

Name (First, Middle Initial, Last) Relationship to taxpayer


City State ZIP Code


3. Purchase/Transferee/New Owner Check if also the Applicant

Relationship to taxpayer

4. Attorney/Representative Information Power of Attorney Form 2848 Attached: Form 8821 or Yes No

Name (First, Middle Initial, Last) Interest Represented (e.g. taxpayer, lender, etc.)


City State ZIP Code


5. Lender/Finance Company Information - or (Settlement/Escrow Company for applications under Section 6325(b)(3) only)

Company Name Contact Name Contact Phone Number

Catalog Number 54727S www.irs.gov Form 14135 (Rev. 06-2010)

Page 2 of 3

6. Monetary Information

Proposed sales price

Expected proceeds to be paid to the United States in exchange for the certificate of discharge (Enter NA if no proceeds are anticipated)

7. Basis for Discharge: Check the box below that best addresses what you would like the United States to consider in your application for discharge. (Publication 783 has additional descriptions of the Internal Revenue Code sections listed below.)

6325(b)(1) Value of property remaining attached by the lien(s) is at least double the liability of the federal tax lien(s) plus other encumbrances senior to the lien(s)

6325(b)(2)(A) The United States receives an amount not less than the value of the United States' interest. (Note: If you are applying under 6325(b)(2)(A) and are the property owner but not the taxpayer, see also section 16.)

6325(b)(2)(B) Interest of the United States in the property to be discharged has no value.

6325(b)(3) Proceeds from property sale held in escrow subject to the liens and claims of the United States.

6325(b)(4) Deposit made or bond furnished in an amount equal to the value of the United States' interest. (Note: This selection provides a remedy under 7426(a)(4) for return of deposit but is exclusively for a property owner not named as the taxpayer on the lien)

8. Description of property (for example, 3 bedroom rental house; 2002 Cessna twin engine airplane, serial number AT919000000000X00; etc.):

Address of real property (If this is personal property, list the address where the property is located):


City State ZIP Code

FOR REAL ESTATE: a legible copy of the deed or title showing the legal description is required Attached NA

FOR Discharge Requests under Section 6325(b)(1): copy of deed(s) or title(s) for property remaining subject to the Federal Tax Lien is required

Attached NA

9. Appraisal and Valuations

REQUIRED APPRAISAL Professional appraisal completed by a disinterested third party Attached

PLUS ONE OF THE FOLLOWING ADDITIONAL VALUATIONS:

County valuation of property (real property) Attached Informal valuation of property by disinterested third party Attached

Proposed selling price (for property being sold at auction) Attached

Other: Attached

AND for applications under Section 6325(b)(1), valuation information (of the type described above in this section) must also be provided for property remaining subject to the lien.


Page 3 of 3 10. Copy of Federal Tax Lien(s) (Complete if applicant and taxpayer differ) Attached No

OR list the lien number(s) found near the top right corner on the lien document(s) (if known)

11. Copy of the sales contract/purchase agreement (if available) Attached No OR Describe how and when the taxpayer will be divested of his/her interest in the property:

12. Copy of a current title report Attached No OR

List encumbrances senior to the Federal Tax Lien. Include name and address of holder; description of encumbrance, e.g., mortgage, state lien, etc.; date of agreement; original loan amount and interest rate; amount due at time of application; and family relationship, if applicable (Attach additional sheets as needed):

13. Copy of proposed closing statement (aka HUD-1) Attached No OR

Itemize all proposed costs, commissions, and expenses of any transfer or sale associated with property (Attach additional sheets as needed):

14. Additional information that may have a bearing on this request, such as pending litigation, explanations of unusual situations, etc., is attached for consideration

Attached No

15. Escrow Agreement (For applications under IRC 6325(b)(3)) Attached No Escrow agreement must specify type of account, name and depositary for account, conditions under which payment will be made, cost of escrow, name and address of any party identified as part of escrow agreement, and signatures of all parties involved including Advisory Group Manager. Terms for agreement must be reached before discharge approved.

16. WAIVER (For applications made by third parties under IRC 6325(b)(2)) If you are applying as an owner of the property and you are not the taxpayer, to have this application considered under section 6325(b)(2), you must waive the rights that would be available if the application were made under section 6325(b)(4). If you choose not to waive these rights, the application will be treated as one made under 6325(b)(4) and any payment will be treated like a deposit under that section. Please check the appropriate box.

I understand that an application and payment made under section 6325(b)(2) does not provide the judicial remedy available under section 7426(a)(4). In making such an application / payment, I waive the option to have the payment treated as a deposit under section 6325(b)(4) and the right to request a return of funds and to bring an action under section 7426(a)(4). Waive No

17. Declaration Under penalties of perjury, I declare that I have examined this application, including any accompanying schedules, exhibits, affidavits, and statements and to the best of my knowledge and belief it is true, correct and complete.

Signature/Title Date




Instructions on how to apply for a Certificate of Subordination of Federal Tax LienA Certificate of Subordination under Internal Revenue Code Section 6325(d)(1) and 6325(d)(2) allows a named creditorto move their junior creditor position ahead of the UnitedStates’ position for the property named in the certificate. For How to Apply for a Certificate of Subordination of Federal Estate Tax Lien Under Section 6325(d)(3) of the InternalRevenue Code use Publication 1153. 1. Complete Form 14134, Application for Certificate ofSubordination of Federal Tax Lien attached with this publication.

2. Mail the completed Form 14134 and the appropriateattachments to: IRS, Attn: Advisory Group Manager(Refer to Publication 4235, Collection Advisory Group Addresses for the correct address. The correct address is the office assigned to the location where the propertyis located.)

If you have any questions, contact the applicable Advisory Office.

If you want to know how much you owe in order to pay thelien(s) in full, call 1-800-913-6050, visit the nearest Taxpayer Assistance Center, or contact the revenue officer assigned to your case.

Important!

Please submit your application at least 45 days beforethe transaction date that the certificate of subordination is needed. Doing so will allow sufficient time for review, de-termination, notification and the furnishing of any applicabledocuments by the transaction date.

Information Required on the Application

Section 1 - Taxpayer Information 1. Enter the name and address of the individual(s) or busi-

ness as it appears on the Notice(s) of Federal Tax Lien (NFTL). A second name line is provided if needed.

2. Enter, if known, the last 4 digits of the social security number (SSN) or full employer identification number asit appears on the NFTL.

3. Enter, if known and if applicable, the last 4 digits of any spousal SSN (secondary SSN) associated with the taxdebt listed on the NFTL.

4. Provide a daytime phone number and a fax number.

Section 2 - Applicant Information 1. Check the box on the first line of Section 2 if you are

both the taxpayer and the applicant. If you are not thetaxpayer, attach a copy of the lien.

2. If you have checked the box indicating that you are the taxpayer and your information is the same as listed onthe lien, enter “same as taxpayer” on the name line.

3. If you are not the taxpayer or you are the taxpayer butyour information is no longer the same as the informa-

tion on the Notice of Federal Tax Lien, enter your name (include any name changes), current address, daytimephone number and fax number.

4. If you are not the taxpayer, enter in the box next to “Name” your relationship to the taxpayer (e.g. parent,uncle, sister, no relation, etc.).

Section 3 - Property Owner 1. Check the box on the first line of Section 3 if you are

both the property owner and the applicant. 2. Enter the name of the property owner. Or if you have

checked the box indicating you are both the applicantand the property owner, enter, “same as applicant”.

3. Enter the property owner’s relationship to the taxpayer(e.g. taxpayer, parent, no relation, etc.).

Section 4 - Attorney/Representative Information This section is used to list the taxpayer’s representative or arepresentative of a party other than the taxpayer, such as the lender, needing to receive information from the IRS. Howev-er, you do not need a representative to request subordination of the federal tax lien.

1. Check the box on the first line of Section 4 if you areattaching a Form 8821 (Tax Information Authority) or Form 2848 (Power of Attorney) with your application. If you are attaching one of these forms, please make sureit is completely filled out, signed, and dated. You must provide one of these forms if the representative repre-sents an interest other than the taxpayer.

2. Enter the name, address, phone number, and fax number of your representative in this action. The IRS will work with you and your representative to process yourapplication. Or enter “NA” on the name line if you arenot using a representative.

3. Enter whose interest the representative represents (e.g.taxpayer, lender, title company, etc.). This allows the IRS to determine what information can be shared with the representative.

Section 5 - Lender/Finance Company Information 1. Enter the company name, contact name, phone number,

and fax number for the lender you are requesting theUnited States subordinate its interest to.

2. Enter the type of transaction. For example, a loanconsolidation or refinance often prompts a subordination request.

Section 6 - Monetary Information 1. Enter the amount of your existing or outstanding financ-

ing. 2. Enter the amount of new financing you are seeking. 3. Enter the amount anticipated being paid toward the

United States’ interest (For applications requested under6325(d)(1) only).

Publication 784 (Rev. 6-2010) Catalog Number 46756T Department of the Treasury Internal Revenue Services www.irs.gov

Section 7 - Basis for Subordination A subordination may be granted under Internal Revenue Code (IRC) 6325(d)(1) or 6325(d)(2). Review the informa-tion below and select the section which best applies to yoursubordination request. If the IRS does not agree with yourselection after its review, an explanation of the decision will be provided.

6325(d)(1) - a subordination may be issued under thissection if you pay an amount equal to the lien or interestto which the certificate subordinates the lien of the United States. The following example uses an 80% loan to valueand a 3% closing cost to financing ratio.

Example: Current/New Original

Fair Market Value $200,000 N/A Refinance $160,000 $145,000 Closing Costs $ 4,800 N/A United States Interest $ 10,200 N/A

In this example the United States’ interest is the equityyou obtain from your refinanced loan after paying off the existing loan of $145,000 and paying the closing coststo obtain the loan. ($200,000 property value x 80%loan to value ratio = $160,000 refinance loan amount. $160,000 - $145,000 loan payoff = $15,000 potential equity. $160,000 x 3% = $4800 closing costs to obtain the loan. $15,000 potential equity - $4,800 closing costs= $10,200) The IRS would ask for $10,200 in return for the United States subordinating its interest to therefinanced loan. The lien remains on the property butthe refinanced loan has priority over the lien.

4. 6325(d)(2) – a subordination may be issued under thissection if the IRS determines that the issuance of the certificate will increase the amount the governmentrealizes and make collection of the tax liability easier. This might involve a refinance to a lower interest ratewhich would, if the subordination were granted, allowa larger monthly repayment rate on the tax liability. Or the situation might be more complex. For example, AAAAuto Sales currently pays the IRS $2000 per month ona $120,000 tax debt. Their inventory needs replenish-ing but their wholesaler is reluctant to provide addedinventory because of the federal tax lien. AAA requests subordination and provides the IRS with documentationthat an inventory replenishment of 500 cars could allowthem to increase their monthly payment to $3000 aswell as increase their pay back rate to bi-weekly. In this example the United States’ interest would be second onthe new inventory, if the subordination is granted. For applications under section 6325(d)(2), completeand attach a signed and dated statement describinghow the amount the United States may ultimately realizethrough this subordination will increase and how collec-tion will be facilitated by the subordination.

5. 6325(d)(3) - Questions and applications for this sectionrefer to Publication 1153 for instructions.

Section 8 - Description of Property 1. Enter a detailed description of the collateral you will use

for the loan or other financing. This is the collateral on which you want the lien interest subordinated to the loanor financing. If this is real estate, you must provide thelegal description.

2. When the property is real estate include the typeof property. For example, 3-bedroom house; etc.When the property is personal property include serialor vehicle numbers, as appropriate. For example,2002 Cessna twin engine airplane, serial numberAT919000000000X00; etc.

3. Provide the property’s physical address if it is real estateor provide the physical address where the property islocated, if it is personal property.

4. Check the appropriate box to indicate whether youattached a copy of the title or deed to the property.

Section 9 - Appraisal and Valuations 1. Check the “Attached” box after “Appraisal” to indicate

whether you have attached an appraisal completed by adisinterested third party. This is typically a professional appraisal providing neighborhood analysis; descrip-tion of the site; description of the improvements; costapproach; comparable sales; definition of market value;certification; contingent and limiting conditions; interiorand exterior photos of the property; exterior photos ofcomparable sales used; comparable sales location map;sketch of subject property showing room layout; floodmap and qualifications of the appraiser. This type ofappraisal is not required for a certificate of subordi-nation.

2. Check the appropriate box under the “Or One of the Following Valuations” section to indicate which type of property value verification is attached with your applica-tion.

Section 10 - Federal Tax Liens This section is important when the applicant and thetaxpayer are different. If the applicant and the taxpayer arethe same, this section may be skipped.

1. Check the “Attached” box if you have attached copies ofthe lien(s) with your application.

2. If you checked the “no” box list the System Lien Identi-fication Number (SLID) found in the top right hand boxof the lien document, if available. If you do not have thenumbers enter “unknown” in the first box.

Section 11 - Proposed loan agreement 1. Check the “attached” box if you have attached the

proposed mortgage contract and describe how subordi-nation is in the best interests of the United States

2. If you checked the “no” box, describe how subordinationis in the best interests of the United States.


Section 12 - Current title report 1. Check the “attached” box if you attached the title report.

This is required for subordination. 2. If you checked the “no” box and the title report is not at-

tached, use the space provided to list any encumbranc-es (liens or claims) against the property and whetherthose encumbrances are senior to the United States’ lien interest. Include the name and address of the holder; description of the encumbrance, e.g., mortgage,state lien, etc.; date of agreement; original loan amountand interest rate; amount due at time of application; andfamily relationship, if applicable.

3. If any mortgages listed on your title report are homeequity lines of credit (HELOCs), the NFTL takes priority over advances made via the HELOC on the 46th dayafter the NFTL is filed. This means any advances madeto you more than 46 days after the NFTL is filed, were made subject to the NFTL. The advances need to be included in the equity interest to which the United Statesattaches. To make an accurate value determination and to avoid processing delays with your application, providedocumentation on any HELOC advances from the 46thday after the NFTL was filed, through the date you submit your application, and include expected advancesthrough the date the certificate will be issued.

4. Attach a separate sheet titled “Section 12” with the infor-mation in item # 2 and # 3 above if there is not enoughspace provided on the form.

Section 13 - Proposed closing statement 1. Check the “attached” box if you attached the proposed

closing statement. This statement is often referred to as a HUD-1.

2. If you checked the “no” box and you did not attach theproposed closing statement, use the space provided toitemize all proposed costs, commissions, and expensesto refinance the property.

3. Attach a separate sheet titled “Section 13” with theinformation in item # 2 above if there is not enoughspace provided on the form.

Section 14 - Additional Information 1. Check the “attached” box if you have attached other

documents relevant to the subordination application.This could include affidavits or court documents.

2. Check the “no” box if you do not have any additionaldocumentation.

Section 15 - Declaration The applicant or their authorized Power of Attorney signs the application form. You must sign your application under penal-ties of perjury attesting to having examined the application,accompanying schedules or documents, exhibits, affidavits,and statements and declaring to the best of your knowledgeand belief that the application is true, correct and complete.

Frequently Asked Questions Q1: When do I make a payment? The Internal Revenue Code section under which the certifi-cate of subordination will be issued or granted determinesthe details regarding making a payment.

• Subordination under 6325(d)(1) requires a payment, butdo not send a payment with the application. The Advisory Group Manager will notify you after determining theamount due and when to send payment. • Subordination under 6325(d)(2) does not require a pay-

ment.

Q2: What is an acceptable form of payment? Make payments in cash or by the following types of checks:certified; cashiers; or treasurer’s check. The check must be drawn on any bank or trust company incorporated underthe laws of the United States, or of any state, or possessionof the United States. Payment can also be made using aUnited States postal, bank, express or telegraph moneyorder.

Important! If you pay by personal check, issuance of thecertificate of subordination will be delayed until the bankhonors the check.

Q3: Who makes the decision to issue a Certificateof Subordination? In all cases Advisory staff will review and verify the informa-tion provided, determine whether a certificate of subordina-tion should be issued, and contact you with any questions.Advisory may contact you, your representative, or anyperson relative to the transaction for additional information.

The Advisory Group Manager has the responsibility to review and approve the determination and let you know theoutcome. If approved, you will receive a conditional commit-ment letter.

Q4: When will I receive the Certificate ofSubordination? The Internal Revenue Code under which the certificate of subordination will be issued or granted determines when youwill receive the certificate. • Under 6325(d)(1), you will receive the certificate upon

receipt of the amount determined to be the interest of theUnited States in the property subject to the federal taxlien. • Under 6325(d)(2), you will receive the certificate after

your application has been investigated and the informa-tion verified. The Advisory Group Manager will notify you of the decision and provide you with a projected date formailing the certificate of subordination.


Q5: What happens if my application is denied? If your application is denied, you will receive Form 9423, Collection Appeal Request and Publication 1660, Collection Appeal Rights, with an explanation of why your applicationwas denied.

Privacy and Paperwork Reduction Act Notice The Privacy act of 1974 says that when we ask you for infor-mation about yourself, we must first tell you our legal right toask for the information, why we are asking for it, and how itwill be used. We must also tell you what could happen if you do not provide it and whether or not you must respond underthe law.

We ask for the information on this form to carry out the Internal Revenue laws of the United States. This information requested on this form is needed to process your applica-tion and to determine whether the federal tax lien can be discharged. You are not required to apply for discharge; however, if you want the federal tax lien to be discharged, you are required to provide the information requested on thisform. Section 6109 requires you to provide the requestedidentification numbers. Failure to provide this information

may delay or prevent processing your application; providingany false information may subject you to penalties.

The time needed to complete and file this form will vary de-pending on individual circumstances. The estimated burden for individuals filing this form is approved under OMB controlnumber 1545-2174. The estimated burden for those who file this form is shown below.

• Recordkeeping 2 hr., 45 min. • Learning about the law or the form 2 hr. • Preparing the form 1 hr., 30 min. • Copying, assembling, and sending the form

to the IRS 85 min. Routine uses of this information include giving it to theDepartment of Justice for civil and criminal litigation, andto cities, states, the District of Columbia, and United States commonwealths and possessions for use in administeringtheir tax laws. Advisory may contact you, your representa-tive, or any person relative to the transaction for additionalinformation. We may also disclose this information to other countries under a tax treaty, to federal and state agencies to enforce federal nontax criminal laws, or to federal law enforcement and intelligence agencies to combat terrorism.


Form 14134 (June 2010)

Application for Certificate of Subordination ofFederal Tax Lien

Department of the Treasury — Internal Revenue Service

OMB No. 1545-2174

Complete the entire application. Enter NA (not applicable), when appropriate. Attachments and exhibits should be included as necessary. Additional information may be requested to clarify the details of the transaction(s).

1. Taxpayer Information (Individual or Business named on the notice of lien)

Name (Individual First, Middle Initial, Last) or (Business) as it appears on lien

Name Continuation (Individual First, Middle Initial, Last) or (Business d/b/a)


Primary Social Security Number

(last 4 digits only)

Secondary Social Security Number

(last 4 digits only)

Employer Identification Number

City State ZIP Code


2. Applicant Information Check if also the Taxpayer (If not the taxpayer, attach copy of lien. See Sec.10)

Name (First, Middle Initial, Last) Relationship to taxpayer


City State ZIP Code


3. Property Owner Check if also the Applicant

Relationship to Taxpayer

4. Attorney/Representative Information Attached: Form 8821 orPower of Attorney Form 2848 Yes No

Name (First, Middle Initial, Last) Interest Represented (e.g. taxpayer, lender, etc.)


City State ZIP Code


5. Lending/Finance Company Company Name Contact Name Contact Phone Number

Type of transaction (For example, loan consolidation, refinance, etc)

Catalog Number 54726H www.irs.gov Form 14134 (Rev. 06-2010)

Page 2 of 3

6. Monetary Information

Amount of existing loan (if refinancing)

Amount of new loan

Amount to be paid to the United States (6325(d)(1) applications only)

7. Basis for Subordination: Check the box below that best addresses what you would like the United States to consider in your application for subordination. (Publication 784 has additional descriptions of the Internal Revenue Code sections listed below.)

6325(d)(1) the United States will receive an amount equal to the lien or interest to which the certificate of subordination is issued (provide amount in Section 6 above)

6325(d)(2) the issuance of the certificate of subordination will increase the government's interest and make collection of the tax liability easier. (Complete and attach a signed and dated statement describing how the amount the United States may ultimately realize will increase and how collection will be facilitated by the subordination.)

Statement Attached NA

8. Description of property (For example, 3 bedroom rental house; 2002 Cessna twin engine airplane, serial number AT919000000000X00; etc.):

Address of real property (If this is personal property list the address where the property is located): Address (Number, Street, P.O. Box)

City State ZIP Code

Real Estate: Legible copy of deed or title showing legal description Attached NA

9. Appraisal and Valuations

Appraisal: (Professional appraisal completed by a disinterested third party but it is not required for a subordination)

Attached

OR ONE OF THE FOLLOWING VALUATIONS:

County valuation of property (real property) Attached

Informal valuation of property by disinterested third party Attached

Proposed selling price (for property being sold at auction) Attached

Other: Attached


No No Yes Yes

Page 3 of 3 10. Copy of Federal Tax Lien(s) (Complete if applicant and taxpayer differ) Attached No

OR list the lien number(s) found near the top right corner on the lien document(s) (if known)

11. Copy of the proposed loan agreement (if available) Attached No AND Describe how subordination is in the best interests of the United States:

12. Copy of a current title report (required for subordination) Attached No OR

List encumbrances with seniority over the Federal Tax Lien. Include name and address of the holder; description of the encumbrance, e.g., mortgage, state lien, etc.; date of agreement; original loan amount and interest rate; amount due at time of application; and family relationship, if applicable. Include any home equity line of credit (HELOCs) advances beginning the 46th day after the NFTL was filed, through the date you submit your application, and include expected advances through the date the certificate will be issued. (Attach additional sheets as needed):

13. Copy of proposed closing statement (aka HUD-1) Attached No OR

Itemize all proposed costs, commissions, and expenses of any transfer or sale associated with property (Attach additional sheets as needed):

14. Additional information that may have a bearing on this request, such as pending litigation, explanations of unusual situations, etc., is attached for consideration

Yes No

15. Declaration Under penalties of perjury, I declare that I have examined this application, including any accompanying schedules, exhibits, affidavits, and statements and to the best of my knowledge and belief it is true, correct and complete.





1. The name and address of the person applying,under section 6325(e) of the Internal RevenueCode, for a certificate of nonattachment.

2. A description of the property for which you arerequesting the certificate of nonattachment; if realproperty is involved, use the description in thetitle or deed of the property and give the completeaddress (street, city, state, and ZIP code).

3. A copy of each Notice of Federal Tax Lien or thefollowing information as it appears on each filednotice: a. The name of the Internal Revenue Office; b. The name and address of the taxpayer

against whom the notice was filed; c. The date and place the notice was filed; and d. The serial number shown on the notice of lien.

Since there is no standard form available for anapplication for a Certificate of Nonattachment ofFederal Tax Lien, a computer-generated requestwill be considered as an application (please, nohandwritten requests). Submit your request andaccompanying attachments to:

IRS, Attn: Advisory Group Manager

(Address to the IRS office in which the lien was filed. Use Publication 4235, Technical Services (Advisory) Group Addresses, to determine where to mail your request.)

Please furnish the following:

How to Prepare an Application for a

Certificate of Nonattachment of Federal Tax Lien

“Under penalties of perjury, I declare that Ihave examined this application, including anyaccompanying schedules, exhibits, affidavits,and statements, and to the best of my knowledgeand belief, it is true, correct, and complete.”

4. Your address at the time the notice of lien wasfiled, and how long you lived at that address.

5. Other residences and the dates you lived at eachfrom the time the notice of lien was filed to thepresent.

6. Your social security number and that of yourspouse.

7. The name, address and telephone number ofyour attorney or other representative, if any.

8. Any other information that might help the AdvisoryGroup Manager decide whether a certificate ofnonattachment should be issued, such as divorcejudgment, partnership agreement or dissolutionagreement.

9. A daytime telephone number where you may bereached.

You should include the following declaration over yoursignature and title:

The Advisory Group Manager may require additionalinformation before issuing the certificate.

Publication 1024 (Rev. 3-2006)Catalog Number 46878I

Department of TreasuryInternal Revenue Service

www.irs.gov

Under the Privacy Act of 1974, the furnishing ofinformation requested in items 4, 5, and 6 is voluntary.It will be used to determine whether a certificate ofnonattachment should be issued. Not providing therequested information may, in some cases, preventthe Advisory Group Manager from issuing a certificate.

Certificate of Release

Instructions on How to Request a

Certificate of Release of Federal Tax Lien

Section 6325(a) of the Internal Revenue Code directsus to release a Federal Tax Lien after a tax liabilitybecomes fully paid or legally unenforceable. We alsomust release a lien when we accept a bond forpayment of the tax.

If we haven’t released the lien within 30 days, youcan ask for a Certificate of Release of Federal TaxLien.

Requesting a Copy of the Certificate

If you have paid the tax you owed and have notreceived a copy of the Certificate of Release ofFederal Tax Lien, you may call 1-800-913-6050.If you prefer to write, see page 2 for the address towhich your request should be mailed or faxed.

The certificate you receive will not show the officialrecording information. For a copy of the recordedcertificate, you must contact the recording officewhere the Certificate of Release of Federal Tax Lienwas filed.

Other Requests

Requests for certificates of release for any otherreason should be mailed to IRS, Attn: TechnicalServices Advisory Group Manager. Use Publication4235, Technical Services Advisory Group Addresses,to determine where to mail your request.

Send your written request with any requireddocuments to the appropriate address.

Your request must contain the followinginformation:

1. The date of your request,2. The name and address of the taxpayer,3. One copy of each Notice of Federal Tax Lien you want released, and4. Why you want us to release the lien.

If you’ve paid the tax, enclose a copy of either of thefollowing:

1. An Internal Revenue receipt,2. A canceled check, or3. Any other acceptable proof.

Please include a telephone number with the best timefor us to call you should we need additionalinformation.

We may need to research your account to confirm youno longer have a liability. We will provide a releaseonce we have done so.

If you have an immediate or urgent need for aCertificate of Release of Federal Tax Lien, visit ortelephone your local IRS office. Be prepared to showproof of payment.

You can pay any unpaid tax with a certified check,cashier’s check, or postal or bank money order toreceive the certificate of release.

Publication 1450 (Rev. 12-2005)Cata log Number 10665H

www.irs.gov

Department of the TreasuryInternal Revenue ServiceInternal Revenue Service

Page 1 of 2

Alabama 205 859-669-3805Alaska 206 859-669-5152Arizona 206 859-669-5152Arkansas 205 859-669-3805California 207 859-669-4954Colorado 206 859-669-5152Connecticut 203 859-669-4954District of Columbia 201 859-669-3805Delaware 201 859-669-3805Florida 201 859-669-3805Georgia 205 859-669-3805Hawaii 206 859-669-5152Idaho 206 859-669-5152Illinois 206 859-669-5152Indiana 206 859-669-5152Iowa 206 859-669-5152Kansas 206 859-669-5152Kentucky 202 859-669-5152Louisiana 205 859-669-3805Maine 203 859-669-4954Maryland 201 859-669-3805Massachusetts 203 859-669-4954Michigan 202 859-669-5152Minnesota 206 859-669-5152Mississippi 205 859-669-3805Missouri 206 859-669-5152Montana 206 859-669-5152Nebraska 206 859-669-5152Nevada 206 859-669-5152New Hampshire 203 859-669-4954New Jersey 202 859-669-5152New Mexico 206 859-669-5152New York 203 859-669-4954North Carolina 201 859-669-3805North Dakota 206 859-669-5152Ohio 202 859-669-5152Oklahoma 205 859-669-3805Oregon 206 859-669-5152

Pennsylvania 202 859-669-3805Puerto Rico 204 859-669-4961Rhode Island 203 859-669-4954South Carolina 201 859-669-3805South Dakota 206 859-669-5152Tennessee 205 859-669-3805Texas 205 859-669-3805Utah 206 859-669-5152Vermont 203 859-669-4954Virginia 201 859-669-3805Washington 206 859-669-3805West Virginia 202 859-669-5152Wisconsin 206 859-669-5152Wyoming 206 859-669-5152

State Team Fax Number State Team Fax Number

Case Processing Address and Phone Numbers

Internal Revenue ServiceCCP - Lien UnitP.O. Box 145595Stop 8420G Team (enter Team Number from list below)Cincinnati, Ohio 45250-5595

Send your written request with any required documents to:

Page 2 of 2

Purchase Money Mortgages

If the IRS has recorded a Notice of Federal Tax Lien(NFTL) against you and you are trying to obtain aloan to buy real or personal property, the followingquestions frequently arise:

Does the lien prevent a bank, mortgage company, orother lender from lending you money to buy a house,a motor vehicle, or other consumer goods or property?

When a loan is made to purchase real property,the lender may obtain a Purchase Money Mortgage(PMM); when a loan is made to purchase personalproperty, the lender may obtain a Purchase MoneySecurity Interest (PMSI). Provided all requirements ofstate law are complied with, these types of financingagreements allow lenders to finance the purchase ofreal and personal property even though a NFTL hasbeen filed against you.

If you borrow money from a lender for such a purposeand give the lender a security interest in the propertypurchased with the proceeds of the loan, will the lender’ssecurity interest have priority over the tax lien?

In 1968 the Internal Revenue Service publishedRevenue Ruling 68-57, which states that it is theposition of the IRS that a PMM or a PMSI givenin good faith to secure a loan for the purchase ofreal property or goods, has priority over an alreadyrecorded Notice of Federal Tax Lien. (See RevenueRuling 68-57 at the end of this publication.)

Is it necessary for the Internal Revenue Service to issuea certificate of subordination giving the security interestpriority over the NFTL?

It is not necessary for the Internal Revenue Serviceto issue a certificate of subordination in order for thelender’s PMM or PMSI to have priority over the lien.

In order for the PMM or PMSI to have priority overthe lien, the PMM or PMSI must meet all of therequirements under state law, including the following.The PMI or PMSI must:

Be allowed under local law – The creation of aPMM or a PMSI is based on state law. While allowedby all states, you or your lender should be familiarwith the laws of the state in which you live. Make surethat your state’s law does not put a limit on the dollaramount of a PMM or a PMSI.

The proceeds of the loan must be used topurchase the property – The PMM or PMSI will havepriority over the federal tax lien in the property you arepurchasing in an amount equal to the proceeds of theloan that are directly used to purchase the property.

If the PMM or PMSI must be recorded – Makesure that the PMM or PMSI is recorded in the placedirected by your state’s law, and that it is recordedwithin any time frame that your state’s law mayrequire.

If the security interest that will be securing the loanyou are making qualifies for the priority given to aPMM or a PMSI, you do not need a certificate ofsubordination from the Internal Revenue Service,and a certificate will not be provided if applied for.

If you or your lender have any questions about whetheryour loan is being secured by a qualifying purchasemoney mortgage or purchase money security interest,please call or write the Technical Services (Advisory)office in your area. Contact information is found inPublication 4235, Technical Services (Advisory) GroupAddresses.

Revenue Ruling 68-57

Section 6321 – LIEN FOR TAXES

26 cfr 301.6321-1: Lien for TaxesRev.Rul. 68-57

The Federal Tax Lien Act of 1966, P.L. 89-719, C.B.1966-2, 623, does not refer to a purchase moneysecurity interest of mortgage. However, the GeneralExplanation of the Act, as set forth in House ofRepresentatives Report No. 1884, C.B. 1966-2, atpage 817, states as follows:

Although so-called purchase money mortgages arenot specifically referred to under present law, it hasgenerally been held that these interests are protectedwhenever they arise. This is based upon the conceptthat the taxpayer has acquired property or a right toproperty only to the extent that the value of the wholeproperty or right exceeds the amount of the purchasemoney mortgage. This concept is not affected by thebill.

In view of the legislative history of the Federal Tax LienAct of 1966, the Internal Revenue Service will considerthat a purchase money security interest or mortgagevalid under local law is protected even though it mayarise after a notice of Federal tax lien has been filed.

Special information relating toPurchase Money Mortgages, Purchase Money Security Interests, andSubordination of the Federal Tax Lien

Publication 785 (10-2005)Catalog Number 47474W

Department of TreasuryInternal Revenue Service

www.irs.gov

Advisory Group Addresses

Collection Advisory Group

Addresses For use when submitting the following certificates related to a Notice of Federal Tax Lien —

• HowtoPrepareanApplicationRequesting theUnitedStatestoReleaseItsRightto RedeemPropertySecuredbyaFederalTax Lien (Publication 487, Catalog No. 46553K)

• InstructionsonhowtoapplyforaCertificate ofDischargeofPropertyFromFederalTax Lien(Publication 783, Catalog No. 46755I)

• HowtoPrepareanApplicationforaCertifi-cateofSubordinationofFederalTaxLien (Publication 784, Catalog No. 46756T)

• SpecialInformationrelatingtoPurchase MoneyMortgages,PurchaseMoneySe-curityInterests,andSubordinationofthe FederalTaxLien(Publication 785, Catalog No. 47474W)

• InstructionsforPreparingaNoticeofNon-JudicialSaleandApplicationforConsentto Sale (Publication 786, Catalog No. 46757E)

• HowtoPrepareanApplicationforaCertifi-cateofNonattachmentofFederalTaxLien (Publication 1024, Catalog No. 46878I)

• ApplicationforWithdrawalofFiledForm 668(Y),NoticeofFederalTaxLien (Form 12277, Catalog No. 27939C)

Publication 4235 (Rev. 6-2010) Catalog Number 37262G Department of the Treasury Internal Revenue Services www.irs.gov

If the Lien Is Filed In: Send Correspondence toIRS Advisory Group at:

Area Location Address Contact # Fax # North Atlantic Connecticut, Maine, Massachusetts, New

Hampshire, Rhode Island, Vermont 15 New Sudbury Street, JFK Building, Rm. 800, PO Box 9112, Stop 20800A, Boston, MA 02203

617-316-2608 617-316-2606

Eastern and Southern New York (Hudson Valley)

1 Clinton Ave. & No. Pearl, Albany, NY 12207

518-427-4178 518-427-4214

Bronx, Manhattan, Rockland, Staten Island and Westchester Counties

290 Broadway Manhattan, NY 10007

212-436-1314 212-436-1203

Brooklyn, Queens and Long Island 10 Metro Center, 625 Fulton St Brooklyn, NY 11201

718-488-2826 718-488-2738

Western and Central New York Room 109, 130 S. Elmwood Ave Buffalo, NY 14202-2464

716-961-5381 716-961-5067

Central Western Pennsylvania 1000 Liberty Ave Room 704, Pittsburgh, PA 15222 412-395-5200 412-395-5291 Eastern Pennsylvania 600 Arch St., Room 3259, Philadelphia, PA 19106 215-861-1328 215-861-1119 New Jersey 4 Paragon Way Suite 2, Freehold, NJ 07728 973-921-4283 732-761-3342 West Virginia, Kentucky, Ohio 550 Main St., Room 3417, Cincinnati, OH 45202 513-263-3197 513-263-4426 Michigan 985 Michigan Ave., 10th Floor, Detroit, MI 48226 313-234-2398 313-234-2261

South Atlantic Virginia 400 North Eighth St., Room 898, Box 75, Richmond, VA 23219

804-916-8039 804-916-8060

Maryland, Delaware, Washington, D.C.

31 Hopkins Plaza, MS 1150 Baltimore, MD 21201

410-962-7298 410-962-9955

North Carolina, South Carolina 320 Federal Place, Room 312 Greensboro, NC 27401

336-378-2414 336-378-2071

Northern Florida 400 West Bay St. Stop 5710, Jacksonville, FL 32202

904-665-0832 904-665-1848

Southern Florida 7850 SW 6th Court, MS 5780, Plantation, FL 33324

954-423-7043 954-423-7809

Midwest Illinois Stop 5012 CHI, 230 S. Dearborn Room 2630, Chicago, IL 60604

312-566-2915 312-566-2999

Indiana Stop SB 461, 575 N. Pennsylvania St, Indianapolis, IN 46204

317-685-7581 317-685-7580

Wisconsin Stop 5303MIL, 211 W. Wisconsin Ave., Milwaukee, WI 53203

414-231-2121 414-231-2123

Missouri, Kansas Stop 5333STL, Rm 9.203, 1222 Spruce St, St. Louis, MO 63103

314-612-4081 314-612-4079

Minnesota, North Dakota, South Dakota Advisory Unit, M/S 5900, 30 E. 7th St. Suite 1222 St. Paul, MN 55101-4940

314-612-4081 651-312-8050

Iowa, Nebraska 1616 Capitol St., Ste. 440, Omaha, NE 68102 402-233-7391 402-223-7480 Gulf States Georgia 401 W. Peachtree St., NW,

Stop 333-D, Atlanta, GA 30308 404-338-8262 404-338-8247

Louisiana, Mississippi, Alabama 1555 Poydras St, Ste 220-Stop 65 New Orleans, LA 70112-3747

504-558-3465 504-558-3490

Tennessee, Arkansas 801 Broadway, MDP 53, Nashville, TN 37203 615-250-5797 615-250-6008 Oklahoma 55 N. Robinson, MS 5021 OKC

Oklahoma City, OK 73102 405-297-4462 405-297-4370

Northern Texas 1100 Commerce St., Mail Code 5028 DAL, Dallas, TX 75242

214-413-5349 214-413-5654

Southern Texas 300 E. Eighth St., MS 5021 AUS Austin, TX 78701

512-499-5241 512-499-5993

Brazoria, Chambers, Fort Bend, Galveston, Hardin, Harris, Jasper, Jefferson, Liberty, Montgomery, Newton, Orange, Polk, San Jacinto, Trinity, Tyler, Walker Counties

1919 Smith St., 5021 HOU Houston, TX 77002

713-209-4515 713-209-3802

Western Colorado, Montana, Utah, Wyoming 1999 Broadway, MS 5021DEN, Denver, CO 80202-2490

303-603-4570 303-382-6327

Alaska, Hawaii, Idaho, Oregon, Washington Arizona, New Mexico, Nevada

915 2nd Ave, MS W245, Seattle, WA 98174 4041 N. Central Ave., MS 5021PHX Phoenix, AZ 85012

206-220-4868 602-636-9358

206-220-5531 602-636-9377

California Imperial, Orange, Riverside, San Bernardino, San Diego Counties

24000 Avila Rd., M/S 5905 Laguna Niguel, CA 92677

949-389-4122 949-389-5004

Los Angeles, Santa Barbara, San Luis Obispo and Ventura Counties

300 N. Los Angeles St., Stop 5021 Los Angeles, CA 90012

213-576-4450 213-576-4401

All California Counties not listed above 1301 Clay St., Ste. 1400S, Oakland, CA 94612 510-637-4660 510-637-2500 All International 7850 SW 6th Court, MS 5780,

Plantation, FL 33324 954-423-7456 954-423-7809

Publication 4235 (Rev. 6-2010) Catalog Number 37262G Department of the Treasury Internal Revenue Services www.irs.gov

Federal Tax Liens Certificates related to a Notice of ......A. IRC § 6325(b)(1) permits discharge if the remaining property of the taxpayer has a fair market value that is double

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