01. International Tax

We provide tailored solutions to complex global businesses doing business in the U.S. Small or multinational, we guide clients through the maze of complex U.S. international tax rules.

02. Offshore Tax Compliance

We assist clients with specialized counsel to fix noncompliance with international tax reporting and penalties. FBAR, forms 8938, 8621, 3520, 926, 5471 and 5472 are among the most common forms that we solve through compliance programs such as streamlined procedures, Voluntary Disclosure Program or the Delinquent International Information Return Submission Procedures (DIIR).

03. Small Business Tax Planning

We assist small and medium businesses with efficient tax structuring to improve efficiencies. Proper tax election, s-corp elections and partnership planning are some of the main solutions offered.

04. Controversy Tax

We guide and represent clients before the IRS including examinations and appeals, as well as represent clients in Tax Court or Federal Courts.

05. Tax Debt Resolution

We help clients to face harsh collection activities, including liens, levies and obtaining a collection alternative such as an offer in compromise, installment payment plans, among others.

06. IRS Criminal Investigations

Our Firm provides representation before IRS Criminal Investigation Division, including Malta Pension Plans and summons.

07. High Net Worth & Family Offices

Assistance with estate planning for select clients and those with cross-border operations, planning for inheritance taxes, and gift taxes in the USA.

08. Start-Ups & Business Tax

No matter how small the idea, we assist clients with the best tax planning and alternatives for their business.

09. Crypto Tax

Our Firm provides tax planning and tax advice on crypto assets and crypto events, including mining, forks, rewards, and disposition/exchange of crypto.

10. BOI Report- Corporate Transparency Act

We assist business owners, CPA and tax preparation firms to file the Beneficial Ownership Information (BOI) report with the FinCEN.

IRS Letter 3172: What It Is and What You Should Do

IRS Notices

08.20.2025

What is IRS Letter 3172?

IRS Letter 3172, formally titled “Notice of Federal Tax Lien Filing and Your Right to a Hearing under IRC 6320”, is an official communication from the IRS informing you that a Federal Tax Lien has been publicly filed. This legal action is based on Internal Revenue Code § 6320, and it signifies that the IRS is asserting a legal claim over your property as a means to secure the collection of unpaid federal taxes.

The lien serves to protect the government’s interest in a taxpayer’s assets until the liability is satisfied or resolved through legal remedies.

What Does Letter 3172 Contain?

IRS Letter 3172 contains key legal and procedural information:

    • The total amount owed, including penalties and accrued interest.
    • The filing date of the lien with the local recorder or registrar.
    • A summary of the legal consequences of the lien.
    • Notice of the taxpayer’s right to a Collection Due Process (CDP) hearing under IRC § 6320.
    • Instructions for filing Form 12153, which must be submitted within 30 calendar days from the date of the letter to exercise appeal rights.

What Are the Legal and Financial Implications of a Federal Tax Lien?

A Federal Tax Lien imposes significant legal and financial consequences. It creates a legal claim by the government against your current and future property and may hinder the sale, refinancing, or transfer of real estate and other assets. It can also negatively impact your credit report and borrowing capacity.

In serious cases, it may even restrict your ability to obtain or renew a U.S. passport.

The lien remains in effect until the debt is fully paid, becomes legally unenforceable, or is released or withdrawn by the IRS.

Your Rights: The Collection Due Process (CDP) Hearing

Pursuant to IRC §§ 6320 and 6330, you have the legal right to request an independent review through a CDP hearing with the IRS Office of Appeals. This hearing allows you to:

    • Challenge the validity of the lien or the amount owed.
    • Propose alternative solutions, such as a payment agreement or an offer in compromise.
    • Demonstrate financial hardship or administrative errors.

To request a hearing, you must submit Form 12153 to the IRS within 30 days of the notice date. The Appeals Office conducts the hearing independently of the IRS collections division.

Resolution Options

The Internal Revenue Code and related regulations provide several resolution options:

    1. Full payment of the tax debt, which leads to lien release within approximately 30 days.
    2. Installment agreement, whereby you make monthly payments.
    3. Offer in Compromise, a settlement agreement for less than the full amount owed, based on inability to pay.
    4. Lien withdrawal, release, or subordination, where appropriate and legally justified.

Each option requires documentation and careful evaluation of your financial circumstances.

Relevance for Taxpayers

Receiving IRS Letter 3172 means the IRS has taken a serious enforcement action. However, it also triggers important taxpayer rights. If you act within the statutory deadlines and seek proper legal guidance, you may be able to eliminate or reduce the lien’s impact, protect your credit and assets, and resolve your tax liabilities.

Timely action and informed legal representation are essential to protecting your rights.

We Can Help!

Facing a federal tax lien alone can be overwhelming. At JH Tax Law, we are dedicated to protecting the rights of taxpayers and resolving complex IRS matters, including those involving IRS Letter 3172.

Contact our office for a confidential consultation today!