What can a lien CDP hearing do?
Lien CDP rights are separate from levy rights. A lien hearing can seek withdrawal, subordination, or discharge of the Notice of Federal Tax Lien and challenge whether it should have been filed.
Are lien and levy hearings the same?
No. Lien CDP rights are separate from levy rights. A Notice of Federal Tax Lien filing (Letter 3172) triggers its own hearing, with its own deadline and its own remedies.
What can you ask for at a lien hearing?
- Withdrawal of the Notice of Federal Tax Lien
- Subordination — allowing another creditor to move ahead of the lien
- Discharge of specific property from the lien
- A challenge to whether the lien filing was appropriate
IRC §6323(j)
The IRS may withdraw a Notice of Federal Tax Lien in specified circumstances — including where withdrawal will facilitate collection, such as entering a direct-debit installment agreement.