What are the three legal requirements for a federal tax lien to arise?

A federal tax lien comes into existence when all three of the following conditions are met:
1. The IRS has assessed the tax (formally recorded the debt),
2. The IRS has sent a Notice and Demand for Payment, and
3. The taxpayer has failed to pay the debt within 10 days of that notice.
Once these steps occur, the lien attaches automatically to the taxpayer\’s property and rights to property.