Pub 784

Instructions on how to apply for a

Certificate of Subordination of Federal Tax Lien

A Certificate of Subordination under Internal Revenue Code
Section 6325(d)(1) and 6325(d)(2) allows a named creditor
to move their junior creditor position ahead of the United
States’ position for the property named in the certificate. For
How to Apply for a Certificate of Subordination of Federal
Estate Tax Lien Under Section 6325(d)(3) of the Internal
Revenue Code use Publication 1153.

1. Complete Form 14134, Application for Certificate of

1. Check the box on the first line of Section 3 if you are
both the property owner and the applicant.

2. Mail the completed Form 14134 and the appropriate

attachments to:
IRS, Attn: Advisory Group Manager
(Refer to Publication 4235, Collection Advisory Group
Addresses for the correct address. The correct address
is the office assigned to the location where the property
is located.)

If you have any questions, contact the applicable Advisory
Office.
If you want to know how much you owe in order to pay the
lien(s) in full, call 1-800-913-6050, visit the nearest Taxpayer
Assistance Center, or contact the revenue officer assigned to
your case.
Important!
Please submit your application at least 45 days before
the transaction date that the certificate of subordination is
needed. Doing so will allow sufficient time for review, determination, notification and the furnishing of any applicable
documents by the transaction date.

Information Required on the Application
Section 1 - Taxpayer Information

1. Enter the name and address of the individual(s) or business as it appears on the Notice(s) of Federal Tax Lien
(NFTL). A second name line is provided if needed.
2. Enter, if known, the last 4 digits of the social security
number (SSN) or full employer identification number as
it appears on the NFTL.

4. Provide a daytime phone number and a fax number.

Section 2 - Applicant Information

4. If you are not the taxpayer, enter in the box next to
“Name” your relationship to the taxpayer (e.g. parent,
uncle, sister, no relation, etc.).

Section 3 - Property Owner

Subordination of Federal Tax Lien attached with this
publication.

3. Enter, if known and if applicable, the last 4 digits of any
spousal SSN (secondary SSN) associated with the tax
debt listed on the NFTL.

tion on the Notice of Federal Tax Lien, enter your name
(include any name changes), current address, daytime
phone number and fax number.

2. Enter the name of the property owner. Or if you have
checked the box indicating you are both the applicant
and the property owner, enter, “same as applicant”.
3. Enter the property owner’s relationship to the taxpayer
(e.g. taxpayer, parent, no relation, etc.).

Section 4 - Attorney/Representative Information
This section is used to list the taxpayer’s representative or a
representative of a party other than the taxpayer, such as the
lender, needing to receive information from the IRS. However, you do not need a representative to request subordination
of the federal tax lien.
1. Check the box on the first line of Section 4 if you are
attaching a Form 8821 (Tax Information Authority) or
Form 2848 (Power of Attorney) with your application. If
you are attaching one of these forms, please make sure
it is completely filled out, signed, and dated. You must
provide one of these forms if the representative represents an interest other than the taxpayer.
2. Enter the name, address, phone number, and fax
number of your representative in this action. The IRS will
work with you and your representative to process your
application. Or enter “NA” on the name line if you are
not using a representative.
3. Enter whose interest the representative represents (e.g.
taxpayer, lender, title company, etc.). This allows the
IRS to determine what information can be shared with
the representative.

Section 5 - Lender/Finance Company Information

1. Enter the company name, contact name, phone number,
and fax number for the lender you are requesting the
United States subordinate its interest to.
2. Enter the type of transaction. For example, a loan
consolidation or refinance often prompts a subordination
request.

1. Check the box on the first line of Section 2 if you are
both the taxpayer and the applicant. If you are not the
taxpayer, attach a copy of the lien.

Section 6 - Monetary Information

2. If you have checked the box indicating that you are the
taxpayer and your information is the same as listed on
the lien, enter “same as taxpayer” on the name line.

2. Enter the amount of new financing you are seeking.

3. If you are not the taxpayer or you are the taxpayer but
your information is no longer the same as the informaPublication 784 (Rev. 6-2010)

Catalog Number 46756T

1. Enter the amount of your existing or outstanding financing.
3. Enter the amount anticipated being paid toward the
United States’ interest (For applications requested under
6325(d)(1) only).
Department of the Treasury Internal Revenue Services

www.irs.gov

Section 7 - Basis for Subordination

Section 8 - Description of Property
1. Enter a detailed description of the collateral you will use

A subordination may be granted under Internal Revenue
Code (IRC) 6325(d)(1) or 6325(d)(2). Review the information below and select the section which best applies to your
subordination request. If the IRS does not agree with your
selection after its review, an explanation of the decision will
be provided.

for the loan or other financing. This is the collateral on
which you want the lien interest subordinated to the loan
or financing. If this is real estate, you must provide the
legal description.

2. When the property is real estate include the type

of property. For example, 3-bedroom house; etc.
When the property is personal property include serial
or vehicle numbers, as appropriate. For example,
2002 Cessna twin engine airplane, serial number
AT919000000000X00; etc.

6325(d)(1) - a subordination may be issued under this
section if you pay an amount equal to the lien or interest
to which the certificate subordinates the lien of the United
States. The following example uses an 80% loan to value
and a 3% closing cost to financing ratio.
Example:
Fair Market Value
Refinance
Closing Costs
United States Interest

3. Provide the property’s physical address if it is real estate

Current/New Original
N/A
$200,000
$160,000
$145,000
$ 4,800
N/A
$ 10,200
N/A

In this example the United States’ interest is the equity
you obtain from your refinanced loan after paying off the
existing loan of $145,000 and paying the closing costs
to obtain the loan. ($200,000 property value x 80%
loan to value ratio = $160,000 refinance loan amount.
$160,000 - $145,000 loan payoff = $15,000 potential
equity. $160,000 x 3% = $4800 closing costs to obtain
the loan. $15,000 potential equity - $4,800 closing costs
= $10,200) The IRS would ask for $10,200 in return
for the United States subordinating its interest to the
refinanced loan. The lien remains on the property but
the refinanced loan has priority over the lien.
4. 6325(d)(2) – a subordination may be issued under this
section if the IRS determines that the issuance of the
certificate will increase the amount the government
realizes and make collection of the tax liability easier.
This might involve a refinance to a lower interest rate
which would, if the subordination were granted, allow
a larger monthly repayment rate on the tax liability. Or
the situation might be more complex. For example, AAA
Auto Sales currently pays the IRS $2000 per month on
a $120,000 tax debt. Their inventory needs replenishing but their wholesaler is reluctant to provide added
inventory because of the federal tax lien. AAA requests
subordination and provides the IRS with documentation
that an inventory replenishment of 500 cars could allow
them to increase their monthly payment to $3000 as
well as increase their pay back rate to bi-weekly. In this
example the United States’ interest would be second on
the new inventory, if the subordination is granted.
For applications under section 6325(d)(2), complete
and attach a signed and dated statement describing
how the amount the United States may ultimately realize
through this subordination will increase and how collection will be facilitated by the subordination.
5. 6325(d)(3) - Questions and applications for this section
refer to Publication 1153 for instructions.

Publication 784 (Rev. -2010)

Catalog Number 46756T

or provide the physical address where the property is
located, if it is personal property.

4. Check the appropriate box to indicate whether you
attached a copy of the title or deed to the property.

Section 9 - Appraisal and Valuations

1. Check the “Attached” box after “Appraisal” to indicate
whether you have attached an appraisal completed by a
disinterested third party. This is typically a professional
appraisal providing neighborhood analysis; description of the site; description of the improvements; cost
approach; comparable sales; definition of market value;
certification; contingent and limiting conditions; interior
and exterior photos of the property; exterior photos of
comparable sales used; comparable sales location map;
sketch of subject property showing room layout; flood
map and qualifications of the appraiser. This type of
appraisal is not required for a certificate of subordination.
2. Check the appropriate box under the “Or One of the
Following Valuations” section to indicate which type of
property value verification is attached with your application.

Section 10 - Federal Tax Liens
This section is important when the applicant and the
taxpayer are different. If the applicant and the taxpayer are
the same, this section may be skipped.

1. Check the “Attached” box if you have attached copies of
the lien(s) with your application.

2. If you checked the “no” box list the System Lien Identi-

fication Number (SLID) found in the top right hand box
of the lien document, if available. If you do not have the
numbers enter “unknown” in the first box.

Section 11 - Proposed loan agreement
1. Check the “attached” box if you have attached the

proposed mortgage contract and describe how subordination is in the best interests of the United States

2. If you checked the “no” box, describe how subordination
is in the best interests of the United States.

Department of the Treasury Internal Revenue Services

www.irs.gov

Section 12 - Current title report
1. Check the “attached” box if you attached the title report.

Frequently Asked Questions

2. If you checked the “no” box and the title report is not at-

The Internal Revenue Code section under which the certificate of subordination will be issued or granted determines
the details regarding making a payment.

This is required for subordination.

tached, use the space provided to list any encumbrances (liens or claims) against the property and whether
those encumbrances are senior to the United States’
lien interest. Include the name and address of the
holder; description of the encumbrance, e.g., mortgage,
state lien, etc.; date of agreement; original loan amount
and interest rate; amount due at time of application; and
family relationship, if applicable.

3. If any mortgages listed on your title report are home

equity lines of credit (HELOCs), the NFTL takes priority
over advances made via the HELOC on the 46th day
after the NFTL is filed. This means any advances made
to you more than 46 days after the NFTL is filed, were
made subject to the NFTL. The advances need to be
included in the equity interest to which the United States
attaches. To make an accurate value determination and
to avoid processing delays with your application, provide
documentation on any HELOC advances from the 46th
day after the NFTL was filed, through the date you
submit your application, and include expected advances
through the date the certificate will be issued.

4. Attach a separate sheet titled “Section 12” with the information in item # 2 and # 3 above if there is not enough
space provided on the form.

1. Check the “attached” box if you attached the proposed
closing statement. This statement is often referred to as
a HUD-1.
2. If you checked the “no” box and you did not attach the
proposed closing statement, use the space provided to
itemize all proposed costs, commissions, and expenses
to refinance the property.
3. Attach a separate sheet titled “Section 13” with the
information in item # 2 above if there is not enough
space provided on the form.

Q2: What is an acceptable form of payment?
Make payments in cash or by the following types of checks:
certified; cashiers; or treasurer’s check. The check 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 using a
United States postal, bank, express or telegraph money
order.
Important! If you pay by personal check, issuance of the
certificate of subordination will be delayed until the bank
honors the check.

In all cases Advisory staff will review and verify the information provided, determine whether a certificate of subordination should be issued, and contact you with any questions.
Advisory may contact you, your representative, or any
person relative to the transaction for additional information.
The Advisory Group Manager has the responsibility to
review and approve the determination and let you know the
outcome. If approved, you will receive a conditional commitment letter.

Q4: When will I receive the Certificate of
Subordination?

Section 14 - Additional Information
1. Check the “attached” box if you have attached other

documents relevant to the subordination application.
This could include affidavits or court documents.

The Internal Revenue Code under which the certificate of
subordination will be issued or granted determines when you
will receive the certificate.

2. Check the “no” box if you do not have any additional
documentation.

Section 15 - Declaration
The applicant or their authorized Power of Attorney signs the
application form. You must sign your application under penalties of perjury attesting to having examined the application,
accompanying schedules or documents, exhibits, affidavits,
and statements and declaring to the best of your knowledge
and belief that the application is true, correct and complete.

Catalog Number 46756T

• Subordination under 6325(d)(1) requires a payment, but
do not send a payment with the application. The Advisory
Group Manager will notify you after determining the
amount due and when to send payment.
• Subordination under 6325(d)(2) does not require a payment.

Q3: Who makes the decision to issue a Certificate
of Subordination?

Section 13 - Proposed closing statement

Publication 784 (Rev. -2010)

Q1: When do I make a payment?

• Under 6325(d)(1), you will receive the certificate upon
receipt of the amount determined to be the interest of the
United States in the property subject to the federal tax
lien.
• Under 6325(d)(2), you will receive the certificate after
your application has been investigated and the information verified. The Advisory Group Manager will notify you
of the decision and provide you with a projected date for
mailing the certificate of subordination.

Department of the Treasury Internal Revenue Services

www.irs.gov

Q5: What happens if my application is denied?
If your application is denied, you will receive Form 9423,
Collection Appeal Request and Publication 1660, Collection
Appeal Rights, with an explanation of why your application
was denied.

Privacy and Paperwork Reduction Act Notice
The Privacy act of 1974 says that when we ask you for information about yourself, we must first tell you our legal right to
ask for the information, why we are asking for it, and how it
will be used. We must also tell you what could happen if you
do not provide it and whether or not you must respond under
the law.
We ask for the information on this form to carry out the
Internal Revenue laws of the United States. This information
requested on this form is needed to process your application and to determine whether the federal tax lien can be
discharged. You are not required to apply for discharge;
however, if you want the federal tax lien to be discharged,
you are required to provide the information requested on this
form. Section 6109 requires you to provide the requested
identification numbers. Failure to provide this information

Publication 784 (Rev. 6-2010)

Catalog Number 46756T

may delay or prevent processing your application; providing
any false information may subject you to penalties.
The time needed to complete and file this form will vary depending on individual circumstances. The estimated burden
for individuals filing this form is approved under OMB control
number 1545-2174. The estimated burden for those who
file this form is shown below.
• Recordkeeping 2 hr., 45 min.
• Learning about the law or the form 2 hr.
• Preparing the form 1 hr., 30 min.
• Copying, assembling, and sending the form
to the IRS 85 min.
Routine uses of this information include giving it to the
Department of Justice for civil and criminal litigation, and
to cities, states, the District of Columbia, and United States
commonwealths and possessions for use in administering
their tax laws. Advisory may contact you, your representative, or any person relative to the transaction for additional
information. We may also disclose this information to other
countries under a tax treaty, to federal and state agencies
to enforce federal nontax criminal laws, or to federal law
enforcement and intelligence agencies to combat terrorism.

Department of the Treasury Internal Revenue Services

www.irs.gov

Form

14134

(June 2010)

Department of the Treasury — Internal Revenue Service

Application for Certificate of Subordination of
Federal Tax Lien

OMB No. 1545-2174

Complete the entire application. Enter NA (not applicable), when appropriate. Attachments and exhibits should be included as
necessary. Additional information may be requested to clarify the details of the transaction(s).

1. Taxpayer Information (Individual or Business named on the notice of lien)
Name (Individual First, Middle Initial, Last) or (Business) as it appears on lien

Primary Social Security Number
(last 4 digits only)

Name Continuation (Individual First, Middle Initial, Last) or (Business d/b/a)

Secondary Social Security Number
(last 4 digits only)

Address (Number, Street, P.O. Box)

Employer Identification Number

City

State

Telephone Number (with area code)

Fax Number (with area code)

2. Applicant Information

ZIP Code

Check if also the Taxpayer (If not the taxpayer, attach copy of lien. See Sec.10)

Name (First, Middle Initial, Last)

Relationship to taxpayer

Address (Number, Street, P.O. Box)
City

State

Telephone Number (with area code)

Fax Number (with area code)

ZIP Code

3. Property Owner

Check if also the Applicant
Relationship to Taxpayer

4. Attorney/Representative Information
Name (First, Middle Initial, Last)

Attached: Form 8821 or
Power of Attorney Form 2848

Yes

No

Interest Represented (e.g. taxpayer, lender, etc.)

Address (Number, Street, P.O. Box)
City

State

Telephone Number (with area code)

Fax Number (with area code)

ZIP Code

5. Lending/Finance Company
Company Name

Contact Name

Contact Phone Number

Type of transaction (For example, loan consolidation, refinance, etc)

Catalog Number 54726H

www.irs.gov

Form 14134 (Rev. 06-2010)

Page 2 of 3

6. Monetary Information
Amount of existing loan (if refinancing)
Amount of new loan
Amount to be paid to the United States (6325(d)(1) applications only)
7. Basis for Subordination: Check the box below that best addresses what you would like the United States to consider
in your application for subordination. (Publication 784 has additional descriptions of the Internal Revenue Code sections listed
below.)

6325(d)(1)

the United States will receive an amount equal to the lien or interest to which the certificate of
subordination is issued (provide amount in Section 6 above)

6325(d)(2)

the issuance of the certificate of subordination will increase the government's interest and make
collection of the tax liability easier. (Complete and attach a signed and dated statement describing how
the amount the United States may ultimately realize will increase and how collection will be facilitated by
the subordination.)

Statement

Attached

NA

8. Description of property (For example, 3 bedroom rental house; 2002 Cessna twin engine airplane, serial number
AT919000000000X00; etc.):

Address of real property (If this is personal property list the address where the property is located):
Address (Number, Street, P.O. Box)
City

State

Real Estate:
Legible copy of deed or title showing legal description

ZIP Code

Attached

NA

9. Appraisal and Valuations
Appraisal: (Professional appraisal completed by a disinterested
third party but it is not required for a subordination)

Attached

OR ONE OF THE FOLLOWING VALUATIONS:
County valuation of property (real property)

Attached

Informal valuation of property by disinterested third party

Attached

Proposed selling price (for property being sold at auction)

Attached

Other:

Attached

Catalog Number 54726H

www.irs.gov

Form 14134 (Rev. 06-2010)

Page 3 of 3

10. Copy of Federal Tax Lien(s) (Complete if applicant and taxpayer differ)

Attached
OR list the lien number(s) found near the top right corner on the lien document(s) (if known)

11. Copy of the proposed loan agreement (if available)

No

Attached

No

Attached

No

AND
Describe how subordination is in the best interests of the United States:

12. Copy of a current title report (required for subordination)
OR

List encumbrances with seniority over the Federal Tax Lien. Include name and address of the holder; description of
the encumbrance, e.g., mortgage, state lien, etc.; date of agreement; original loan amount and interest rate; amount
due at time of application; and family relationship, if applicable. Include any home equity line of credit (HELOCs)
advances beginning the 46th day after the NFTL was filed, through the date you submit your application, and include
expected advances through the date the certificate will be issued. (Attach additional sheets as needed):

13. Copy of proposed closing statement (aka HUD-1)

Attached

No

OR
Itemize all proposed costs, commissions, and expenses of any transfer or sale associated with property (Attach
additional sheets as needed):

14. Additional information that may have a bearing on this request,
such as pending litigation, explanations of unusual situations, etc.,
is attached for consideration

Yes

No

15. Declaration
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.

Catalog Number 54726H

Signature/Title

Date

Signature/Title

Date
www.irs.gov

Form 14134 (Rev. 06-2010)