If you received a lien hearing notice in East Aurora, NY while your collection case is still open, the first decision is not whether you agree with the lien — it is whether you can preserve the Collection Due Process deadline. Under IRC 6320 and IRM 5.1.9, the IRS must give written notice of appeal rights after an NFTL filing, and that right depends on timely action. The safest move is to identify the notice type, confirm the “must file by” date, and send a written request to the address shown on the notice before the window closes.
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A lien hearing notice is usually Letter 3172, which is different from a levy notice. For a filed Notice of Federal Tax Lien, the IRS uses the filing office’s recording date and the mailing rules in IRM 5.1.9 to set the deadline. That means the date on the notice matters, but so does whether the request is actually sent to the correct IRS address listed on that notice.
If the notice also mentions levy action, do not assume the same deadline applies in the same way. IRM 5.1.9 explains that lien hearings and levy hearings are separate CDP events, even though they can sometimes be consolidated. Reading the notice carefully now avoids a late request caused by using the wrong form or the wrong mailing address.
Use records that prove timeliness, not just disagreement
The most useful records are the notice itself, the envelope or mailing label if you still have it, a dated copy of your written request, and proof of how it was sent. If you mail the request, keep the postal receipt and track delivery. If you hand-deliver it or fax it using a number on the notice, save the confirmation page or stamped copy.
If the IRS later says it did not receive your request, IRM 5.1.9 says the taxpayer may need to show a copy of what was sent. A timely postmark to the proper IRS address can matter, but only if the mailing fits the notice instructions. Do not rely on a general explanation that you meant to appeal; preserve the paper trail now.
What to include in the request
A CDP request should clearly identify the periods shown on the notice and state that you want a Collection Due Process hearing. If you do not want to dispute every period listed, you can exclude a specific period that is not in issue. That keeps the request focused and can avoid confusion about what Appeals should review.
If your goal is to discuss why the lien filing should not continue or should be reconsidered, explain the issue in plain language and attach supporting documents. A hypothetical example would be a taxpayer who received a lien notice on an account already in an approved resolution process; the taxpayer could ask Appeals to review why the filing was still appropriate and provide the approval paperwork. That example is only illustrative, and the result still depends on the facts and the IRS record.
Take the next practical step before the deadline slips
Do not wait for every financial record before preserving the deadline. You can file a timely request first and then gather supporting documentation for the hearing. If the request is late, IRM 5.1.9 says it may be treated as an Equivalent Hearing request instead, which is not the same procedural posture as a timely CDP case.
If you need to confirm the notice or request address, use the address printed on the notice and, if needed, the IRS local office locator or TAS contact page for general guidance. That does not mean a local office decides your collection case. The practical goal is simple: file in time, keep proof, and then build the substantive argument for Appeals.
Questions about A lien hearing notice during a pending collection case
Does a lien hearing notice stop collection by itself?
No. A timely CDP request can affect how the case moves forward, but it does not automatically erase the debt or guarantee that collection activity will stop. The notice creates a hearing right; it is not a promise of a particular outcome.
Can I ask for both a lien and levy hearing at once?
If the IRS issued both notices, the request may cover both and Appeals can consolidate them. The key is to identify each notice and include the relevant periods so the hearing request matches what the IRS actually sent.
What if I mailed the request to the wrong IRS office?
IRM 5.1.9 says the request should be sent or hand-delivered to an IRS office and address on the CDP notice. If you believe you sent it elsewhere, keep a copy of what was filed and be ready to show proof, because timeliness can turn on where and how it was delivered.
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Sources and related resources
Tax.Directory IRS guidance and FAQs · IRSDecoder notice explanations · ETSVideos
Executive Tax Solution resources
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General educational guidance. Relief and collection protections depend on the actual notices, account history, financial evidence, and applicable law. A consultation does not itself stop enforcement or preserve an appeal deadline.
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