The IRS will send you a Notice of Your Right to a Collection Due Process Hearing within five business days of filing the NFTL. You’ll have 30 days (the date will be shown in the notice) to request a Collection Due Process (CDP) hearing with the IRS Independent Office of Appeals. See Publication 1660, Collection Appeal Rights, for a full explanation of the CDP process. If you wish to appeal the proposed filing of the NFTL, you need to timely complete and mail Form 12153, Request for a Collection Due Process or Equivalent Hearing. If you do not file Form 12153, you will lose the ability to contest the Appeals’ CDP decision in the U.S. Tax Court. If your request for a CDP hearing isn’t timely, you can request an Equivalent Hearing within one year from the date of the CDP notice, but you can’t go to Tax Court if you disagree with the Appeals’ decision. At the CDP hearing, you may raise many issues which include proposing an alternative way to pay your debt, such as an installment agreement or offer in compromise, and in certain instances, to contest the existence or amount of the tax, but only if you did not receive a notice of deficiency or did not otherwise have an opportunity to dispute the tax liability.

If the IRS has already issued a CDP notice for that particular tax debt, then you can still request a hearing with the IRS Independent Office of Appeals either before or after the IRS files an NFTL. You will need to request a conference through the Collection Appeals Program (CAP), but unlike a CDP hearing, you may not seek review of Appeals’ decision in the U.S. Tax Court. See Publication 1660, Collection Appeal Rights, for a full explanation of the CAP.

You can also ask that the IRS manager review your case informally. You can obtain the manager’s name and phone number by contacting the employee listed on your notice. IRS employees are required to give you their manager’s name and phone number when requested.

Once a lien arises, the IRS generally can’t release it until you’ve paid the tax, penalties, interest, and recording fees in full or until the IRS is no longer legally able to collect the tax. However, in certain circumstances a lien may be withdrawn, discharged, or subordinated. Visit Liens on TAS Get Help for further information.