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What is the IRS’s interest in a taxpayer’s assets based upon the NFTL?
PostedNovember 17, 2025
UpdatedNovember 17, 2025
ByKlemens Raab
The IRS is said to \”step into the shoes of the taxpayer,\” and so the IRS\’s interest is the same as the taxpayer\’s interest in the same assets.
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IRS Tax Liens
- What is the "silent lien" in IRS collections?
- What are the three legal requirements for a federal tax lien to arise?
- What is a Notice of Federal Tax Lien (NFTL)?
- Can the IRS file an NFTL even if the taxpayer owes less than $50,000?
- What is the IRS's interest in a taxpayer's assets based upon the NFTL?
- What does it mean for a lien to be "choate"?
- Do federal tax liens always take priority over other liens?
- What are "super-priority" liens?
- Why do mortgage companies pay delinquent property taxes on behalf of borrowers?
- How can a family loan be protected from IRS collection actions?
- Under what conditions will the IRS consider withdrawing an NFTL?
- Are IRS tax liens self-releasing?
- Can the IRS refile a lien just to extend its time to collect taxes?
- Where does the IRS typically file an NFTL?
- Does an IRS lien affect a spouse's property if the spouse is not on the lien?
- What is the taxpayer's right to a hearing after a lien is filed?
- Can a taxpayer sell a home that has an IRS tax lien on it?
- What if the taxpayer sells the property in a short-sale and will not receive any money from the deal?
- What is a subordination of a tax lien?
- What is a Certificate of Non-Attachment?
- What are alter ego and nominee liens?
- Show all articles (7) Collapse Articles

