Pub 784

How to Prepare an Application for a

Certificate of Subordination of Federal Tax Lien
There is no standard form available for an
application for a Certificate of Subordination
of Federal tax lien. Prepare your request in the
form of a typed letter and submit it with all
accompanying documents to:
IRS, Attn: Technical Services Group Manager
(Address to the IRS office that filed the lien. Use
Publication 4235, Technical Services Group Addresses,
to determine where to mail your request.)

Information Required on Application
Give date of the application.
Give the name and address of the person applying for the certificate of subordination under either
section 6325(d)(1) or 6325(d)(2) of the Internal
Revenue Code. See the “Additional Information” section
of this publication for applicable Internal Revenue Code
sections. Give the name and address of the taxpayer,
and describe the property as follows:

4. List or attach a copy of the liens, mortgages or
other encumbrances against the property that you
believe have priority over the Federal tax lien. For
each encumbrance show:
a. The name and address of the holder
b. A description of the encumbrance
c. The date of the agreement to the encumbrance
d. The date and place of the recording, if any
e. The original principal amount and the interest
rate
f. The amount due as of the date of the application, if known (show costs and accrued
interest separately)
g. Your family relationship, if any, to the taxpayer
and to the holders of any other encumbrances
on the property
5. Instead of the information in 4a through f above, you
may substitute a preliminary title report listing the
required information.

1. Give a detailed description, including the location
of the property for which you are requesting the
certificate of subordination. If real property is
involved, submit a legible copy of the title or deed
to the property and the complete address (street,
city, state, and ZIP code).

6. The name and address of any new mortgage holder
to which you are requesting the federal tax lien be
subordinated, the amount of the proposed loan, and
a schedule showing all fees and expenses related
to obtaining the loan.

2. Attach a copy of each notice of Federal tax
lien, or furnish the following information as it
appears on each filed notice of Federal tax lien:

7. Furnish an estimate of the fair market value of the
property for which you would like a certificate
of subordination.

a. The location of the Internal Revenue
Office that filed the lien
b. The name and address of the taxpayer
against whom the notice was filed
c. The date and place the notice was
filed
d. The taxpayer social security number or
employer identification number shown
on the lien

8. If you are submitting the application under section
6325(d)(1), show the amount to be paid to the
United States.

3. Submit a copy of each instrument to which you
believe an encumbrance exists or describe the
encumbrance to which the Federal tax lien is to
be subordinated, including:

10. Furnish any other information that might help the
Technical Services Group Manager decide whether
to issue a certificate of subordination.

a. The present amount of the encumbrance
b. The nature of the encumbrance (such as
mortgage, assignment, etc.)
c. The date the transaction is to be completed

9. If you are submitting the application under section
6325(d)(2), attach a complete statement showing
how the amount the United States may realize
will ultimately increase and how collection of the
tax liability will be made easier.

11. The Technical Services Group Manager may
request that you furnish additional information.
12. Give a daytime telephone number where you may
be reached.
(over)

13. Give the name, address and telephone number of
your attorney or other representative, if any.
14. Write the following declaration over your
signature and title: ''Under penalties of perjury, I
declare that I have examined this application, including any accompanying schedules, exhibits, affidavits,
and statements, and to the best of my knowledge
and belief it is true, correct, and complete.''

Additional Information
Before applying for a certificate of subordination,
determine how much you owe in order to pay the lien(s)
in full. You may obtain a payoff by calling 1-800-9136050 or by visiting the nearest IRS Taxpayer Assistance
Center. If you have the ability to borrow enough to full
pay the amount you owe, we will usually not issue a
certificate of subordination.
The Technical Services Group Manager has the authority to issue a certificate of subordination of a lien that is
filed on any part of a taxpayer's property subject to the
lien. The following sections and provisions of the Internal
Revenue Code apply:
Section 6325(d)(1) - If you pay an amount equal to the
lien or interest to which the certificate subordinates the
lien of the United States.
Section 6325(d)(2) - If the Tehnical Services Group
Manager believes that issuance of the certificate will
increase the government’s interest, and make collection
of the tax liability easier. This applies to the property
that the certificate is for or any other property subject to
the lien.

Department of Treasury
Internal Revenue Service

1. No payment is required for the issuance of a
certificate under section 6325(d)(2) of the Code.
Payment is required for certificates issued under
section 6325(d)(1). However, do not send the
payment with your application. The Technical
Services Group Manager will notify you after
determining the amount due.
2. The Technical Services Group Manager will
have your application investigated to determine
whether to issue the certificate and will let you
know the outcome.
3. A certificate of subordination under section
6325(d)(1) will be issued upon receipt of the
amount determined to be the interest of the
United States in the subject property under
the Federal tax lien. Make payments in cash,
or by a certified, cashier's, or treasurer's
check. It must be drawn on any bank or trust
company incorporated under the laws of the
United States, or of any state, or possession
of the United States. Payment can also be
made by United States postal, bank, express,
or telegraph money order. (If you pay by personal check, issuance of the certificate of subordination will be delayed until the bank honors
the check.)

4. In certain cases the Technical Services Group
Manager may require additional information such
as written appraisals by disinterested third parties,
a list of all the taxpayer's property, or other information needed to make a determination.

www.irs.gov

Publication 784 (Rev. 8-2005)
Catalog Number 46756T