Form 668(Y)(c): Reading a Notice of Federal Tax Lien
Form 668(Y)(c) is the Notice of Federal Tax Lien, the public document the IRS records in the office a state designates under 26 U.S.C. § 6323(f). It lists each assessment by kind of tax, period, assessment date, last day for refiling and unpaid balance. Under § 6320, Letter 3172 must follow within 5 business days.
This page reads the document itself: where it is recorded, what each column means, its release clause, and the hearing letter that comes with it. How the lien works, and the full release, withdrawal, discharge and subordination procedures, are in the federal tax lien guide.
Deadline to know: Under § 6320(a)(3)(B), the 30-day period to request a Collection Due Process hearing begins the day after the 5-business-day window for sending Letter 3172. Publication 1660 says the letter states the date the period expires, and a Form 12153 request must be postmarked by then.
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What Form 668(Y)(c) is
Section 6323(f)(3) leaves the notice’s “form and content” to the Treasury. IRM 5.12.1 names the result Form 668(Y)(c), Notice of Federal Tax Lien, a computer-generated form from the IRS Automated Lien System (ALS). The “c” means “continuous,” a printing format the IRS once used; manually prepared templates may read Form 668(Y), and the IRM says all versions will move to the label Form 668-Y.
The paper does not create the lien, which § 6322 says arises when the assessment is made. The bold statement at the top, quoted in IRM 5.12.7.2, cites sections 6321, 6322 and 6323 and says a demand for payment was made, the liability “remains unpaid,” and a lien exists “on all property and rights to property belonging to this taxpayer.” One notice can list up to 15 assessments (Publication 1468), and a copy is enclosed with Letter 3172 (IRM 5.12.6.3.5).
Where the notice is filed
Section 6323(f)(1) sends the notice to one office within the state, chosen by state law:
- Real property: the designated office where the property is physically located.
- Personal property: the designated office for the taxpayer’s residence when the notice is filed. Under § 6323(f)(2), a corporation or partnership resides at its principal executive office, and a taxpayer residing abroad is treated as residing in the District of Columbia.
- Fallbacks: the clerk of the U.S. district court where a state designates no office, and the Recorder of Deeds for property in the District of Columbia.
Publication 594 gives county recorder of deeds and Secretary of State offices as examples. IRM 5.12.7 notes that “Names of recording offices may be different in different states,” that many states use the Secretary of State for personal property of corporations, partnerships and other entities, and that its Exhibit 5.12.7-2 lists each state’s office. The form’s Place of Filing field names the office (IRM 5.12.8), and Publication 1450 says a certificate of release is filed in that same office.
Reading the form, field by field
The IRM names each field in its lien filing instructions and exhibits. Column letters appear where the IRM gives them.
| Field | What it shows |
|---|---|
| Serial Number | An ALS identifier, “found near the top of the document” (Form 12277) |
| Name and address | Who owes the liability |
| Kind of Tax (column a) | The type of tax by tax form; restitution shows an “R” prefix, such as R1040 |
| Tax Period Ended | The period each assessment covers |
| Identifying Number | SSN or EIN, partially redacted, such as xx-xxx-1234 (IRM 5.12.7.3) |
| Date of Assessment (column d) | The statutory lien date, used to compute the refiling date |
| Last Day for Refiling (column e) | 10 years and 30 days from the column d date |
| Unpaid Balance of Assessment (column f) | The assessed amount when the notice was filed |
| Place of Filing | The recording office |
The dollar column is not a payoff. Publication 1468 says it “is the assessed amount at the time of filing the document” and stays on the public record until the lien is satisfied; current figures come from the Centralized Lien Operation (800-913-6050), and payoff computations “may take up to 14 calendar days to process.” IRM 5.12.7 notes one exception: when the assessed amount is paid but accruals remain, the column shows the accrued amount as of the request date.
The self-release clause and the Last Day for Refiling
Directly under the name and address (Publication 1468), the form prints this clause, quoted in IRM 5.12.7.2: “IMPORTANT RELEASE INFORMATION: For each assessment listed below, unless notice of the lien is refiled by the date given in column (e), this notice shall, on the day following such date, operate as a certificate of release as defined in IRC 6325(a).”
Section 6322 keeps the lien until the liability is satisfied or “becomes unenforceable by reason of lapse of time”; § 6502(a) generally limits collection by levy or court proceeding to 10 years after assessment; and § 6325(a) requires a certificate of release no later than 30 days after the IRS finds the assessed amount paid or no longer enforceable.
Column (e) marks the end of the first required refiling period in § 6323(g)(3)(A), “the one-year period ending 30 days after the expiration of 10 years after the date of the assessment of the tax.” IRM 5.12.3 cautions that this date “is not the CSED” (collection statute expiration date); the two match, as CSED plus 30 days, only when the collection period has not been extended.
What happens on the day after
- With no refile, IRM 5.12.8 says the statutory lien and the notice are both released “even if the collection statute remains open.” A refile on Form 668-F is not self-releasing (IRM 5.12.3).
- Each assessment has its own release point, and Publication 1468 says the notice is not fully released until every listed liability is satisfied or self-released.
- No certificate is issued automatically for a self-released lien, but IRM 5.12.3 says one should be issued on request once the liabilities are satisfied or unenforceable.
- If column (e) reads “N/A” or is blank, IRM 5.12.8 says the clause does not operate and a certificate of release is required. Publication 1468 says the refiling period for such a notice is the same as any other.
Questions about a lien notice or its dates?
An attorney can review the form, the Letter 3172 deadline, and the certificate routes that fit the facts.
Letter 3172: the hearing notice that comes with the form
Section 6320(a) requires written notice of the filing, delivered in person, left at home or the usual place of business, or sent by certified or registered mail “not more than 5 business days after the day of the filing of the notice of lien.” IRM 5.12.6 identifies it as Letter 3172, Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 6320, also called the “CDP lien notice.”
By statute the letter states the unpaid tax, the hearing right, available appeals, release rules and the § 7345 passport rules. IRM 5.12.6.3.5 says it repeats the periods, tax types, assessment dates and balances on the notice, and encloses Form 668(Y)(c), Publication 594, Publication 1450, Publication 1660 and Form 12153.
When it is sent, and when it is not
Letter 3172 goes out when a notice is first filed for a tax period, or when a later notice for that period adds an assessment. It is not issued for a filing in another jurisdiction covering periods already noticed, for new interest and penalty accruals, or for a refiled notice (IRM 5.12.6.3.5). A representative with a power of attorney receives Letter 3262, and a later filing for periods already noticed brings Letter 3171 (IRM 5.12.6).
Counting the 30 days
Sources put the timing two ways. The statute and Publication 1660 begin the 30 days after the 5-business-day period, and Publication 1660 says the letter “will indicate the date this 30-day period expires.” The IRS CDP FAQ says simply that “Letter 3172 gives you 30 days.” Publication 1660 treats the printed date as the postmark deadline and allows one lien hearing per tax period. The hearing itself is explained in the federal tax lien guide.
Clearing the record: the certificates in brief
Each route ends with a document filed in the office named on the form. Eligibility and application steps are in the federal tax lien guide.
| Route | Law | Form or publication |
|---|---|---|
| Release after payment or lapse | § 6325(a) | Publication 1450 |
| Release of an erroneous filing | § 6326 | Appeal; certificate states the error |
| Withdrawal of the notice | § 6323(j) | Form 12277 |
| Discharge of a named property | § 6325(b) | Form 14135; Publication 783 |
| Subordination to a named creditor | § 6325(d) | Form 14134; Publication 784 |
Form 12277 asks for a copy of the Form 668(Y) or, without one, its serial number, filing date and recording office. Publication 1450 says the taxpayer’s copy of a release certificate “will not show the official recording information,” which comes from the recording office, and Publication 1468 says the taxpayer pays the office’s fees to file and release the lien. For an erroneous filing, § 6326(b) calls for a certificate, to the extent practicable, “within 14 days after such determination.”
When an attorney matters
Publication 1660 says a taxpayer may appear alone at CDP and CAP proceedings or be represented by an attorney, a certified public accountant or a person enrolled to practice before the IRS; a representative acting without the taxpayer needs Form 2848, Power of Attorney and Declaration of Representative. The roles differ in a few places:
- Tax Court. IRM 5.12.6.3.3 allows 30 calendar days after a CDP lien determination to petition the U.S. Tax Court, which admits attorneys by application and nonattorneys who meet its Rules, including an examination.
- Privilege. Section 7525 extends attorney-style confidentiality to federally authorized tax practitioners only in noncriminal tax matters.
The attorney vs CPA vs enrolled agent comparison covers the roles in more depth.
Related guides
Frequently Asked Questions
What is IRS Form 668(Y)(c)?
It is the Notice of Federal Tax Lien, which the IRS files in a state or county recording office under § 6323(f). The “c” stands for “continuous,” an old printing format.
Where is a Notice of Federal Tax Lien filed?
In the one office state law designates. For real estate that is where the property sits; for personal property it is where the taxpayer lives when the notice is filed. Publication 594 names county recorder of deeds and Secretary of State offices.
What does the Last Day for Refiling on Form 668(Y)(c) mean?
It ends the first refiling window under § 6323(g), 10 years and 30 days after assessment. Without a refile by then, the form’s release clause makes the notice operate as a certificate of release for that assessment.
Is the balance on Form 668(Y)(c) the payoff amount?
No. Publication 1468 says the amount shown is the assessed amount when the notice was filed. A current payoff figure comes from the Centralized Lien Operation at 800-913-6050.
How long is there to respond to Letter 3172?
Section 6320 allows 30 days to request a hearing, starting after the 5-business-day period for sending the letter. Publication 1660 says the letter shows the end date, and Form 12153 must be postmarked by then.
Talk through a lien notice before its dates pass
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Ray Neu
Ray Neu is the publisher of IRSAttorneys.net. A former law enforcement officer with a background in criminal justice and digital publishing, he oversees editorial direction, partnership standards, and compliance review for the site. He is not an attorney and does not provide legal advice; all tax law content is sourced and reviewed against the standards documented on the Editorial Team & Standards page.
Sources
- IRS: Understanding a federal tax lien
- IRM 5.12.1, Lien Program Overview
- IRM 5.12.3, Lien Release and Related Topics
- IRM 5.12.6, Appeals Processes Involving Liens
- IRM 5.12.7, Notice of Lien Preparation and Filing
- IRM 5.12.8, Notice of Lien Refiling
- IRS Publication 1468 (01-2014)
- IRS Publication 1450 (Rev. 7-2018)
- IRS Publication 594 (Rev. 1-2026)
- IRS Publication 1660 (Rev. 1-2020)
- IRS Form 12277 (PDF)
- IRS Form 14135 (PDF)
- IRS Form 14134 (PDF)
- IRS Publication 783 (PDF)
- IRS Publication 784 (PDF)
- IRS Form 12153 (PDF)
- IRS: Collection Due Process (CDP) FAQs
- 26 U.S.C. § 6320, Notice of lien filing and hearing
- 26 U.S.C. § 6322, Period of lien
- 26 U.S.C. § 6323, Validity and priority
- 26 U.S.C. § 6325, Release and discharge
- 26 U.S.C. § 6326, Appeal of liens
- 26 U.S.C. § 6502, Collection after assessment
- 26 U.S.C. § 7525, Practitioner privilege
- U.S. Tax Court: Practitioners
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