Can the IRS file a lien without notifying me first?
The IRS can create an automatic statutory lien without notifying you, and this happens the moment you have assessed tax debt, receive a demand for payment, and fail to pay. This silent lien exists but is not public. However, the IRS must send you a Notice of Federal Tax Lien Filing (usually via Letter 3172 or CP501/CP503/CP504 notices) within 5 business days of filing the public Notice of Federal Tax Lien (NFTL) with your county recorder. The NFTL is the public document that alerts creditors and affects your ability to sell property or get credit. You have the right to request a Collection Due Process (CDP) hearing within 30 days of receiving the lien filing notice. During the CDP hearing, you can challenge the lien, propose alternatives (installment agreement, OIC), or argue that the lien is causing undue hardship. If you miss the 30-day CDP window, you can still file an Equivalent Hearing request within one year, though this doesn't have the same appeal rights.
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