On the paper
Review the filing date, the tax periods, the amount, and the recording office information shown in the letter.
Check the tax periods on the lien notice against the periods you believe are open. A Notice of Federal Tax Lien covers the assessments listed on it and no others, so a period missing from the list is not encumbered by that filing, and a period you thought was resolved appearing on the list is a discrepancy worth chasing before the hearing period runs.
Find the date printed on your notice or letter. The paper notice and the current official IRS instructions control, even where this page differs.
Where this notice comes from
The federal tax lien arises by statute when tax is assessed, demand is made, and the tax goes unpaid. Filing the Notice of Federal Tax Lien is a separate act that makes the claim public and fixes priority against certain third parties.
That is why the hearing this letter offers is about the filing rather than about the tax. Appeals considers whether the filing was proper and whether an alternative, such as withdrawal, discharge, or subordination, should be used.
The letter arrives after the filing rather than before it, because the statute gives the IRS 5 business days after filing to send the notice and then runs the hearing period from that point.
General next steps
- Compare the periods and balances on the letter against your records and earlier IRS correspondence.
- Read the instructions for Form 12153 and note the address the letter gives for it.
- Keep the letter with any proof of payment, release, or prior agreement covering the listed periods.
Timing
IRS Appeals states, in the page on letters and notices offering an appeal opportunity checked September 10, 2026, that Form 12153 should be sent to the address on the lien notice within 30 days from the date of the letter. 26 U.S.C. section 6320(a)(3)(B) sets the request period as the 30 days beginning the day after the 5 business days the IRS has to send the notice. The date printed on the notice controls; do not calculate a deadline from this page.
What Letter 3172 does not mean
A lien filing is not a levy. Nothing has been taken. The filing is a public record of a claim against property, and its effect is on credit, on sale, and on priority against other creditors rather than on your bank account. It also does not create the tax debt, which existed from assessment, notice, and nonpayment before any filing.
What this page cannot tell you
This page cannot determine whether a lien should be withdrawn, released, discharged, or subordinated in your circumstances.
IRS Appeals
This letter may offer a Collection Due Process hearing with the IRS Independent Office of Appeals. Read IRS Appeals.
How do I respond to an IRS collection notice?
Read the paper notice first. Identify the letter code, the assessed balance, and any date printed on it. Read How do I respond to an IRS collection notice?.
IRS collections
This letter involves an unpaid IRS balance or a collection action. Read IRS collections.
Federal tax lien
The lien itself, and how release, withdrawal, discharge, and subordination work, are explained on a separate page. Read Federal tax lien.
Form 12153
A Collection Due Process or equivalent hearing is requested on Form 12153, sent to the hearing address printed on the notice rather than the payment address. Read Form 12153.
Governing statute
26 U.S.C. section 6320 requires the IRS to notify a taxpayer that a Notice of Federal Tax Lien has been filed, not more than 5 business days after the filing, and to give an opportunity for a Collection Due Process hearing during the 30-day period that begins the day after that 5-day period. The section was checked on uscode.house.gov on September 10, 2026. That is the authority, not advice about this notice.
Official sources
- IRS letters and notices offering an appeal opportunity
- IRS Collection Due Process FAQs
- 26 U.S.C. section 6320, notice and opportunity for hearing upon filing of notice of lien
If anything on this page differs from your notice or from current IRS instructions, follow the notice and the IRS.
Common questions
Does the lien take my property?
No. A lien is a claim; a levy is a taking. The filing affects priority against other creditors and appears in the public record, and the IRS uses a separate process with separate notice requirements to seize anything.
Can the filing be withdrawn?
The IRS publishes criteria for withdrawal, release, discharge, and subordination, each of which answers a different problem. A hearing on the filing is one place those alternatives can be raised.
Does paying the balance remove the lien from the record?
Payment leads to a release of the lien. Release and withdrawal are not the same thing, and the record of the filing is treated differently under each.