Federal Tax Liens: Filing, Release, Withdrawal, and Discharge

Categories: IRS CE, IRS Resolution
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About Course

This advanced two-hour continuing education course provides an in-depth examination of federal tax liens — their creation, filing, priority, release, withdrawal, discharge, and subordination — expanding on the introductory treatment of federal tax lien attachment, priority, and certificates that appears in the broader IRS Collections course. This course does not repeat that introductory material; it addresses the statutory mechanics and practitioner procedures in the depth a practitioner actually needs when a lien is standing in the way of a real transaction.

Related Courses

What Will You Learn?

  • Apply IRC Section 6321 and 6322 to determine when a federal tax lien arises, what it attaches to, and how long it continues
  • Explain the effect of filing a Notice of Federal Tax Lien under IRC Section 6323(a) on priority against purchasers, security interest holders, mechanic's lienors, and judgment lien creditors
  • Apply the refiling requirements of IRC Section 6323(g) and identify the required refiling period
  • Distinguish a Certificate of Release under IRC Section 6325(a) from a withdrawal under IRC Section 6323(j) in both legal effect and practical consequence
  • Identify the four statutory grounds for withdrawal under IRC Section 6323(j) and complete a withdrawal request using Form 12277
  • Apply the five grounds for discharge under IRC Section 6325(b) and complete a discharge request using Form 14135, including required timing
  • Apply IRC Section 6325(d) to identify when subordination is available and complete a request using Form 14134
  • Distinguish release, withdrawal, discharge, and subordination from one another and select the correct remedy for a given client scenario

Course Content

Module 1 – Legal Foundations — Lien Creation, Attachment, and Duration
<p>Legal Foundations — Lien Creation, Attachment, and Duration</p>

  • Legal Foundations — Lien Creation, Attachment, and Duration

Module 2 – Notice of Federal Tax Lien — Filing and Priority
<p>Notice of Federal Tax Lien — Filing and Priority</p>

Module 3 – Certificate of Release and Withdrawal
<p>Certificate of Release and Withdrawal</p>

Module 4 – Discharge and Subordination
<p>Discharge and Subordination</p>

Final Assessment – Federal Tax Liens: Filing, Release, Withdrawal, and Discharge
This final assessment consists of 10 multiple-choice questions covering all four modules of this course. A passing score of 70% or better is required.

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