Tax Relief AnswersIRS Letter 3172: Tax Lien Filed and Your Hearing Right
The short answer
Letter 3172, "Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320," tells you the IRS has filed a public Notice of Federal Tax Lien against you. Under 26 U.S.C. 6320 the IRS must send it within 5 business days after the filing, and you then have a 30-day period, starting the day after those 5 business days, to request a Collection Due Process (CDP) hearing. The letter prints the exact "request your hearing by" date. Sources: 26 U.S.C. 6320, IRS, Collection Due Process FAQs and IRS Publication 1660, checked November 3, 2026. The IRS has no "Understanding your Letter 3172" page; we also used its published sample of the letter.
What Letter 3172 is
| Question | Answer, from the statute and IRS sources |
|---|---|
| Legal basis | 26 U.S.C. 6320 (notice and hearing after a lien is filed) |
| What already happened | The IRS filed Form 668(Y)(c), Notice of Federal Tax Lien; a copy comes with the letter |
| When it must be sent | Not more than 5 business days after the lien is filed, in person, left at your home or business, or by certified or registered mail (6320(a)(2)) |
| Hearing deadline | 30 days, beginning the day after that 5-business-day period (6320(a)(3)(B)); the letter shows the date |
| How to ask | Form 12153, Request for a Collection Due Process or Equivalent Hearing |
| Who hears it | The IRS Independent Office of Appeals, with an officer who had no prior involvement (6320(b)) |
| Late request | An equivalent hearing, if postmarked within one year plus 5 business days after the lien filing date (Publication 1660) |
| Hearings per period | One CDP lien hearing per tax period (6320(b)(2)) |
What the lien means
The IRS sample letter explains that a tax lien generally attaches to everything you own now and will own later, that the notice is a public record, and that it may damage your credit rating or make credit harder to get. It also says the IRS will issue Form 668(Z), Certificate of Release of Federal Tax Lien, within 30 days if you pay the full amount including penalties and interest, if the IRS accepts a bond for the amount owed, or if it decides you do not owe the liability. A lien is a claim, not a seizure; see lien vs levy and federal tax lien.
Where it sits in the collection sequence
- Bill and reminders: CP14, CP501 and CP503. The reminders warn that a lien may be filed.
- CP504: Notice of Intent to Levy; a lien may also be filed.
- Lien filed, then Letter 3172 within 5 business days.
- Final levy notice with its own hearing right: LT11 or Letter 1058.
Steps
- Find the "request your hearing by" date on page 2 of the letter.
- Check the tax periods and balances listed against your records.
- If you want a hearing, complete Form 12153 and mail it to the address on the letter before that date. The IRS FAQ says to request a CDP hearing if you feel the lien is inappropriate. At a CDP hearing you can also discuss payment options.
- If you can pay in full, pay; the release follows within 30 days, the letter says.
- If you cannot, apply for an IRS payment plan or ask about other options in the hearing.
- Read our appeals guide for the difference between CDP and the Collection Appeals Program.
Common mistakes
- Missing the date. After it, only an equivalent hearing is available, and Publication 1660 says you cannot go to court if you disagree with Appeals' decision in an equivalent hearing.
- Treating the lien as a levy. The lien secures the debt; taking property requires a separate levy notice with hearing rights.
- Ignoring the passport section. Once a lien is filed and these hearing rights lapse or are used, a large enough debt can be certified under 26 U.S.C. 7345; see CP508C.
- Paying a company to make a lien disappear. Release, withdrawal and hearing requests are free IRS processes.
A Low Income Taxpayer Clinic can represent you in a CDP hearing for free or a small fee if you qualify, and the Taxpayer Advocate Service is free. Not sure the letter is real? See how to check an IRS letter.
FAQ
How long do I have to respond to Letter 3172?
You have 30 days to request a CDP hearing, starting the day after the 5-business-day period after the lien was filed. The letter prints the exact date.
What form do I use to request a hearing on Letter 3172?
Form 12153, Request for a Collection Due Process or Equivalent Hearing. The IRS FAQ points to it when you feel the lien is inappropriate.
What if I miss the Letter 3172 deadline?
Publication 1660 says you can still ask for an equivalent hearing if the request is postmarked within one year plus 5 business days after the lien filing date.
Does Letter 3172 mean the IRS will take my property?
No. It reports a lien filing. A levy on wages, bank accounts or other property needs a separate notice of intent to levy with hearing rights.