Resources
Working guides on federal tax liens in real estate transactions.
Each of these pages is a working reference — written by a federal tax attorney, covering the procedures that matter when a closing is on the line.
Lien Solutions
The six procedural paths for clearing or working around a federal tax lien on property.
Certificate of Discharge
IRC §6325(b)
The procedure that removes a lien from one specific property so a sale can close. The flagship tool for saving an active closing.
Lien Subordination
IRC §6325(d)
Moves a new loan ahead of the federal tax lien in priority. Unlocks refinances blocked by tax liens.
Lien Withdrawal
IRC §6323(j)
Removes the Notice of Federal Tax Lien from the public record as if never filed. The DDIA Fresh Start pathway.
Lien Release
IRC §6325(a)
The automatic release when the underlying debt is satisfied by payment, OIC, bond, or CSED expiration.
Full Payment at Closing
Simplest path
When sale proceeds cover the full lien balance, the title company pays the IRS at settlement.
Collection Alternatives
IA · OIC · CNC · CSED
The five paths to resolution of the underlying tax debt after the lien is cleared.
Transaction Issues
IRS issues that kill deals in other ways — tax consequences of the transaction itself, levies, buyer-side qualification problems, estate-specific complications.
Short Sale Tax Issues
IRC §108
The 1099-C cancellation of debt income trap and the §108 exclusions that prevent a tax disaster.
§121 Home Sale Exclusion
IRC §121
The $250,000/$500,000 gain exclusion and the traps that disqualify otherwise-eligible sellers.
Levy on Closing Proceeds
IRC §6331
When the IRS levies on sale proceeds at closing — and how to get the levy released.
Buyer DTI Trap
Installment Agreements & Mortgage Qualification
How an IRS payment plan silently kills buyer mortgage qualification — and the workarounds.
Estate Sale Tax Liens
IRC §6324
The automatic estate tax lien on taxable estates, plus the decedent's income tax liens that survive.
Tools for Agents
Practical takeaways built for real estate professionals.
When a lien surfaces, move fast.
The first conversation is free. The second one usually saves the deal.