How to Apply for a 

Certificate of Subordination of Federal 
Estate Tax Lien Under Section 6325(d) 
of the Internal Revenue Code 

Since there is no standard form available for an application                    4.	   List the encumbrances (or attach a copy of the instrument that 
for a certificate of subordination of Federal Estate tax lien,                      created each encumbrance) on all the property subject to the 
a  typewritten request will  be considered an  application.                         estate tax lien, that you believe has priority over the estate tax 
Submit your typewritten request and all accompanying                                lien. For each encumbrance show: 
documents to:                                                                         a.	  The name and address of the holder; 
                                                                                    b.	   A description of the encumbrance; 
Address application to:                                                               c.	  The date of the agreement; 
     Internal Revenue Service                                                       d.	   The date and place of any recording; 
     Advisory Estate Tax Lien Group                                                   e.	  The original principal amount and the interest rate; 
     55 South Market St. Mail Stop 5350                                               f.	  The amount due, if known, as of the date of the application for 
     San Jose, CA 95113-2324                                                            certificate  of subordination  (show  costs  and  accrued  interest 
     Attn: Group Manager                                                                separately); 
     E-fax number: 877-477-9243                                                       g.	  Your family relationship, if any, to the holder(s) of any other 
                                                                                        encumbrances on the property. 
Give date of application:                                                       Also show the following: 
Please give the name and address of the person applying,                        5.	   An estimate of the fair market value of the property for which 
under section 6325(d) of the Internal Revenue Code, for a                           you would like a certificate of subordination, the basis of this 
certificate of subordination. Give the name and address of                          estimate, and a separate estimate of any remaining property 
the decedent at the time of death and describe the property                         subject to the estate tax lien. 
as follows:                                                                       6.	  The name address, and social security numbers of the  
                                                                                    decedent’s estate or any qualified heir(s) of property subject to  
1.	   Give a detailed description, including the location, of the 
                                                                                    the notice of Federal estate tax lien. 
     property for which you are requesting the certificate of 
     subordination. If real property is involved, use the description             7.	  If the applicant or the applicant’s legal representative is not  
     contained in the title or deed to the property, and the complete               the agent designated by the estate, executor or the qualified  
     address (street, city, State, and ZIP code).                                   heir(s) for dealings with Internal Revenue Service regarding  
                                                                                    the property, submit a written authorization for the applicant or  
2.	   Attach a copy of each notice of Federal estate tax lien, or                   representative to apply for a subordination of the estate tax lien. 
     furnish the following information as it appears on each filed 
                                                                                8.	   The purpose of the loan for which the subordination is sought. 
     notice of Federal tax lien: 
                                                                                9.	   The amount of money to be loaned to the applicant, the terms 
       a.	  The name of the Internal Revenue Area; 
     b.	   The name and address of the taxpayer against whom the notice             of repayment, and the exact name of address of the lender. 
         was filed;                                                                 Please include the name and telephone number of a contact 
       c.	  Serial number shown on the lien;                                        person in the lender’s office. 
     d.	   Taxpayer’s identification number shown on the lien;                  10.   A daytime telephone number where you can be reached. 
       e.	  The date and place the notice was filed; 
       f.	  In lieu of the above, a preliminary title report may be substituted 11.   The name, address, and telephone number of your attorney or 
         listing the required information.                                          other legal representative. 
3.	  Describe the encumbrance to which the Federal estate tax lien  12.  Make       the following declaration over your signature and title: 
     is to be subordinated, including:                                              “Under penalties of perjury, I declare that I have examined this 
       a.	  The present or proposed amount of the encumbrance, or both;             application (including any accompanying schedules, exhibits, 
     b.	   The nature of the encumbrance (such as mortgage, assignment,             affidavits,  and  statements)  and to  the best  of my  knowledge  and 
         etc.);                                                                     belief, it is true, correct, and complete.” 
       c.	  The date the transaction is to be completed. 

         Publication 1153 (Rev. 6-2018)  Catalog Number 62173C  Department of the Treasury  Internal Revenue Service            www.irs.gov