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How to Apply for a

Certificate of Subordination of Federal Tax Lien

A Certificate of Subordination under Internal Revenue Code Notice of Federal Tax Lien, enter your name (include any
Section 6325(d)(1) and 6325(d)(2) allows a named creditor to name changes), current address, daytime phone number
move their junior creditor position ahead of the United States’ and fax number.
position for the property named in the certificate. For How to 4. If you are not the taxpayer, enter in the box next to “Name”
Apply for a Certificate of Subordination of Federal Estate Tax your relationship to the taxpayer (e.g. parent, uncle, sister,
Lien Under Section 6325(d)(3) of the Internal Revenue Code use no relation, etc).
Publication 1153.
Section 3 - Property Owner
1. Complete Form 14134, Application for Certificate of
Subordination of Federal Tax Lien, attached with this 1. Check the box on the first line of Section 3 if you are both
publication. the property owner and the applicant.
2. Mail the completed Form 14134 and the appropriate 2. Enter the name of the property owner. Or if you have
attachments to: checked the box indicating you are both the applicant and
IRS Advisory Consolidated Receipts the property owner, enter, “same as applicant”.
7940 Kentucky Drive, Stop 2850F 3. Enter the property owner’s relationship to the taxpayer (e.g.
Florence, KY 41042 taxpayer, parent, no relation, etc.).
(Refer to Publication 4235, Collection Advisory Group
Addresses, for additional contact information.) Section 4 - Attorney/Representative Information
If you have any questions, contact the Advisory Consolidated This section is used to list the taxpayer’s representative or a
Receipts Office at 859-594-6090. representative of a party other than the taxpayer, such as the
lender, needing to receive information from the IRS. However,
If you want to know how much you owe in order to pay the you do not need a representative to request discharge of the
lien(s) in full, call 1-800-913-6050, visit the nearest Taxpayer federal tax lien.
Assistance Center, or contact the revenue officer assigned to
your case. 1. Check the box on the first line of Section 4 if you are
attaching a Form 8821 (Tax Information Authority) or Form
Important! 2848 (Power of Attorney) with your application. If you
Please submit your application at least 45 days before the are attaching one of these forms, please make sure it is
transaction date that the certificate of subordination is needed. completely filled out, signed, and dated. You must provide
Doing so will allow sufficient time for review, determination, one of these forms if the representative represents an
notification and the furnishing of any applicable documents by interest other than the taxpayer.
the transaction date. 2. Enter the name, address, phone number, and fax number
of your representative in this action. The IRS will work with
Information Required on the Application you and your representative to process your application.
Or enter “NA” on the name line if you are not using a
Section 1 - Taxpayer Information representative.
1. Enter the name and address of the individual(s) or business 3. Enter whose interest the representative represents (e.g.
as it appears on the Notice(s) of Federal Tax Lien (NFTL). A taxpayer, lender, title company, etc.). This allows the IRS
second name line is provided if needed. to determine what information can be shared with the
2. Enter, if known, the last 4 digits of the social security representative.
number (SSN) or full employer identification number as it
Section 5 – Lender/Finance Company Information
appears on the NFTL.
1. Enter the company name, contact name, phone number,
3. Enter, if known and if applicable, the last 4 digits of any
and fax number for the lender you are requesting the
spousal SSN (secondary SSN) associated with the tax debt
United States subordinate its interest to.
listed on the NFTL.
2. Enter the type of transaction. For example, a loan
4. Provide a daytime phone number and a fax number. consolidation or refinance often prompts a subordination
Section 2 - Applicant Information request.
1. Check the box on the first line of Section 2 if you are both Section 6 – Monetary Information
the taxpayer and the applicant. If you are not the taxpayer, 1. Enter the amount of your existing or outstanding financing.
attach a copy of the NFTL.
2. Enter the amount of new financing you are seeking.
2. If you have checked the box indicating that you are the
taxpayer and your information is the same as listed on the 3. Enter the amount anticipated being paid toward the United
NFTL, enter “same as taxpayer” on the name line. States’ interest (For applications requested under 6325(d)
(1) only).
3. If you are not the taxpayer or you are the taxpayer but your
information is no longer the same as the information on the

Publication 784 (Rev. 12-2022) Catalog Number 46756T Department of the Treasury Internal Revenue Services www.irs.gov

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Section 7 - Basis for Subordination which you want the lien interest subordinated to the loan or
A subordination may be granted under Internal Revenue Code financing. If this is real estate, you must provide the legal
(IRC) 6325(d)(1) or 6325(d)(2). Review the information below description.
and select the section which best applies to your subordination 2. When the property is real estate include the type of
request. If the IRS does not agree with your selection after its property. For example, 3-bedroom house; etc. When the
review, an explanation of the decision will be provided. property is personal property include serial or vehicle
numbers, as appropriate. For example, 2002 Cessna twin
6325(b)(1) – a subordination may be issued under this section engine airplane, serial number AT919000000000X00; etc.
if you pay an amount equal to the lien or interest to which
the certificate subordinates the lien of the United States. The 3. Provide the property’s physical address if it is real estate or
following example uses an 80% loan to value and a 3% closing provide the physical address where the property is located,
cost to financing ratio. if it is personal property.
Example 4. Check the appropriate box to indicate whether you
attached a copy of the title or deed to the property
Current/New Original
Fair Market Value $200,000 N/A Section 9 – Appraisal and Valuations
Refinance $160,000 $145,000 1. Check the “Attached” box after “Appraisal” to indicate
Closing Costs $4,800 N/A whether you have attached an appraisal completed by a
United States Interest $10,200 N/A disinterested third party. This is typically a professional
appraisal providing neighborhood analysis; description of
In this example the United States’ interest is the equity the site; description of the improvements; cost approach;
you obtain from your refinanced loan after paying off the comparable sales; definition of market value; certification;
existing loan of $145,000 and paying the closing costs to contingent and limiting conditions; interior and exterior
obtain the loan. ($200,000 property value x 80% loan to photos of the property; exterior photos of comparable
value ratio = $160,000 refinance loan amount. $160,000 - sales used; comparable sales location map; sketch of
$145,000 loan payoff = $15,000 potential equity. $160,000 subject property showing room layout; flood map and
x 3% = $4800 closing costs to obtain the loan. $15,000 qualifications of the appraiser. This type of appraisal is
potential equity - $4,800 closing costs = $10,200) The not required for a certificate of subordination.
IRS would ask for $10,200 in return for the United States
subordinating its interest to the refinanced loan. The lien 2. Check the appropriate box under the “Or One of the
remains on the property but the refinanced loan has priority Following Valuations” section to indicate which type
over the lien. of property value verification is attached with your
application.
4. 6325(d)(2) – a subordination may be issued under this
section if the IRS determines that the issuance of the Section 10 − Notices of Federal Tax Lien (NFTLs)
certificate will increase the amount the government realizes This section is important when the applicant and the taxpayer
and make collection of the tax liability easier. This might are different. If the applicant and the taxpayer are the same, this
involve a refinance to a lower interest rate which would, section may be skipped.
if the subordination were granted, allow a larger monthly
repayment rate on the tax liability. Or the situation might 1. Check the “Attached” box if you have attached copies of
be more complex. For example, AAA Auto Sales currently the NFTL with your application.
pays the IRS $2000 per month on a $120,000 tax debt. 2. If you checked the “no” box list the System Lien
Their inventory needs replenishing but their wholesaler is Identification Number (SLID) found in the top right hand
reluctant to provide added inventory because of the federal box of the NFTL document, if available. If you do not have
tax lien. AAA requests subordination and provides the IRS the numbers enter “unknown” in the first box.
with documentation that an inventory replenishment of 500
cars could allow them to increase their monthly payment Section 11 − Proposed loan agreement
to $3000 as well as increase their pay back rate to bi-
1. Check the “attached” box if you have attached the
weekly. In this example the United States’ interest would
proposed mortgage contract and describe how
be second on the new inventory, if the subordination is
subordination is in the best interests of the United States
granted.
2. If you checked the “no” box, describe how subordination is
For applications under section 6325(d)(2) complete, and
in the best interests of the United States.
attach a signed and dated statement describing how the
amount the United States may ultimately realize through Section 12 − Current Title Report
this subordination will increase and how collection will be
facilitated by the subordination. 1. Check the “attached” box if you attached the title report.
This is required for subordination.
5. 6325(d)(3) – Questions and applications for this 2. If you checked the “no” box and the title report is not
sectionrefer to Publication 1153 for instructions. attached, use the space provided to list any encumbrances
(liens or claims) against the property and whether those
Section 8 – Description of Property
encumbrances are senior to the United States’ lien interest.
1. Enter a detailed description of the collateral you will use Include the name and address of the holder; description
for the loan or other financing. This is the collateral on of the encumbrance, e.g., mortgage, state lien, etc.;

Publication 784 (Rev. 12-2022) Catalog Number 46756T Department of the Treasury Internal Revenue Services www.irs.gov

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date of agreement; original loan amount and interest rate; Q2: What is an acceptable form of payment?
amount due at time of application; and family relationship, if Make payments in cash or by the following types of checks:
applicable. certified; cashiers; or treasurer’s check. The check must be
3. If any mortgages listed on your title report are home equity drawn on any bank or trust company incorporated under the
lines of credit (HELOCs), the NFTL takes priority over laws of the United States, or of any state, or possession of
advances made via the HELOC on the 46th day after the the United States. Payment can also be made using a United
NFTL is filed. This means any advances made to you more States postal, bank, express or telegraph money order.
than 46 days after the NFTL is filed, were made subject to
the NFTL. The advances need to be included in the equity Important! If you pay by personal check, issuance of the
interest to which the United States attaches. To make an certificate of subordination will be delayed until the bank honors
accurate value determination and to avoid processing the check.
delays with your application, provide documentation on any
HELOC advances from the 46th day after the NFTL was Q3: Who makes the decision to issue a Certificate of
filed, through the date you submit your application, and Subordination?
include expected advances through the date the certificate
In all cases Advisory staff will review and verify the information
will be issued.
provided, determine whether a certificate of subordination
4. Attach a separate sheet titled “Section 12” with the should be issued, and contact you with any questions. Advisory
information in item # 2 and # 3 above if there is not enough may contact you, your representative, or any person relative to
space provided on the form. the transaction for additional information.
Section 13 − Proposed closing statement The Advisory Group Manager has the responsibility to review
1. Check the “attached” box if you attached the proposed and approve the determination and let you know the outcome.
closing statement. This statement is often referred to as a If approved, you will receive a conditional commitment letter.
HUD-1.
Q4: When will I receive the Certificate of Subordination?
2. If you checked the “no” box and you did not attach the
proposed closing statement, use the space provided to The Internal Revenue Code under which the certificate of
itemize all proposed costs, commissions, and expenses to subordination will be issued or granted determines when you
refinance the property will receive the certificate.
3. Attach a separate sheet titled “Section 13” with the • Under 6325(d)(1), you will receive the certificate upon
information in item # 2 above if there is not enough space receipt of the amount determined to be the interest of the
provided on the form. United States in the property subject to the federal tax lien.
Section 14 − Additional Information • Under 6325(d)(2), you will receive the certificate after your
application has been investigated and the information
1. Check the “attached” box if you have attached other
verified. The Advisory Group Manager will notify you of the
documents relevant to the subordination application. This
decision and provide you with a projected date for mailing
could include affidavits or court documents.
the certificate of subordination.
2. Check the “no” box if you do not have any additional
documentation. Q5: What happens if my application is denied?
If your application is denied, you will receive Form 9423,
Section 15 − Declaration
Collection Appeal Request, and Publication 1660, Collection
The applicant or their authorized Power of Attorney signs Appeal Rights, with an explanation of why your application was
the application form. You must sign your application under denied.
penalties of perjury attesting to having examined the application,
accompanying schedules or documents, exhibits, affidavits, and Privacy and Paperwork Reduction
statements and declaring to the best of your knowledge and
belief that the application is true, correct and complete. Act Notice
The Privacy act of 1974 says that when we ask you for
Frequently Asked Questions information about yourself, we must first tell you our legal right
to ask for the information, why we are asking for it, and how it
Q1: When do I make a payment? will be used. We must also tell you what could happen if you do
The Internal Revenue Code section under which the certificate not provide it and whether or not you must respond under the
of subordination will be issued or granted determines the details law.
regarding making a payment. We ask for the information on this form to carry out the Internal
• Subordination under 6325(d)(1) requires a payment, but Revenue laws of the United States. This information requested
do not send a payment with the application. The Advisory on this form is needed to process your application and to
Group Manager will notify you after determining the amount determine whether the federal tax lien can be subordinated.
due and when to send payment. You are not required to apply for subordination; however, if you
want the federal tax lien to be subordinated, you are required
• Subordination under 6325(d)(2) does not require a payment. to provide the information requested on this form. Section 6109

Publication 784 (Rev. 12-2022) Catalog Number 46756T Department of the Treasury Internal Revenue Services www.irs.gov

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requires you to provide the requested identification numbers. Routine uses of this information include giving it to the
Failure to provide this information may delay or prevent Department of Justice for civil and criminal litigation, and
processing your application; providing any false information to cities, states, the District of Columbia, and United States
may subject you to penalties. commonwealths and possessions for use in administering their
tax laws. Advisory may contact you, your representative, or any
The time needed to complete and file this form will vary person relative to the transaction for additional information.
depending on individual circumstances. The estimated burden We may also disclose this information to other countries
for individuals filing this form is approved under OMB control under a tax treaty, to federal and state agencies to enforce
number 1545-2174. The estimated burden for those who file federal nontax criminal laws, or to federal law enforcement and
this form is shown below. intelligence agencies to combat terrorism.
• Recordkeeping 2 hr., 45 min.
• Learning about the law or the form 2 hr.
• Preparing the form 1 hr., 30 min.
• Copying, assembling, and sending the form to the IRS 85
min.

Publication 784 (Rev. 12-2022) Catalog Number 46756T Department of the Treasury Internal Revenue Services www.irs.gov

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                                     Department of the Treasury — Internal Revenue Service 
                                                                                                                       OMB No. 1545-2174
Form 14134            Application for Certificate of Subordination of
(June 2010) 
                                                 Federal Tax Lien 
Complete the entire application.  Enter NA (not applicable), when appropriate.  Attachments and exhibits should be included as 
necessary.  Additional information may be requested to clarify the details of the transaction(s). 
1. Taxpayer Information (Individual or Business named on the notice of lien) 
Name (Individual First, Middle Initial, Last) or (Business) as it appears on lien                 Primary Social Security Number 
                                                                                                  (last 4 digits only) 
Name Continuation (Individual First, Middle Initial, Last)  or(Business d/b/a)                    Secondary Social Security Number 
                                                                                                  (last 4 digits only) 
Address (Number, Street, P.O. Box)                                                                Employer Identification Number 

City                                                 State                                        ZIP Code 

Telephone Number (with area code)                    Fax Number (with area code) 

2. Applicant Information                         Check if also the Taxpayer (If not the taxpayer, attach copy of lien. See Sec.10) 
Name (First, Middle Initial, Last)                                                Relationship to taxpayer 

Address (Number, Street, P.O. Box) 

City                                                 State                                        ZIP Code 

Telephone Number (with area code)                    Fax Number (with area code) 

3. Property Owner                                                                            Check if also the Applicant 
                                                                                  Relationship to Taxpayer 

4. Attorney/Representative Information               Attached:  Form 8821 or                 Yes  No
                                                     Power of Attorney Form 2848 
Name (First, Middle Initial, Last)                                                Interest Represented (e.g. taxpayer, lender, etc.) 

Address (Number, Street, P.O. Box) 

City                                                 State                                        ZIP Code 

Telephone Number (with area code)                    Fax Number (with area code) 

5. Lending/Finance Company 
Company Name                                         Contact Name                                 Contact Phone Number 

Type of transaction (For example, loan consolidation, refinance, etc) 

Catalog Number 54726H                                         www.irs.gov                         Form 14134 (Rev. 06-2010)

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                                                                                                                  Page 2 of 3 
6. Monetary Information 

Amount of existing loan (if refinancing) 

Amount of new loan 

Amount to be paid to the United States (6325(d)(1) applications only) 

7. Basis for Subordination: Check the box below that best addresses what you would like the United States to consider 
in your application for subordination. (Publication 784 has additional descriptions of the Internal Revenue Code sections listed 
below.) 

6325(d)(1)            the United States will receive an amount equal to the lien or interest to which the certificate of 
                      subordination is issued (provide amount in Section 6 above) 

6325(d)(2)            the issuance of the certificate of subordination will increase the government's interest and make 
                      collection of the tax liability easier. (Complete and attach a signed and dated statement describing how 
                      the amount the United States may ultimately realize will increase and how collection will be facilitated by 
                      the subordination.) 

                      Statement    Attached  NA 

8. Description of property (For example, 3 bedroom rental house;  2002 Cessna twin engine airplane, serial number 
AT919000000000X00; etc.): 

Address of real property (If this is personal property list the address where the property is located): 
Address (Number, Street, P.O. Box) 

City                                         State                                ZIP Code 

Real Estate: 
Legible copy of deed or title showing legal description                           Attached NA 

9. Appraisal and Valuations 
Appraisal: (Professional appraisal completed by a disinterested                   Attached 
           third party but it is not required for a subordination) 

OR ONE OF THE FOLLOWING VALUATIONS: 
County valuation of property (real property)                                      Attached 
Informal valuation of property by disinterested third party                       Attached 
Proposed selling price (for property being sold at auction)                       Attached 
Other:                                                                            Attached 

Catalog Number 54726H                                         www.irs.gov                  Form 14134 (Rev. 06-2010)

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                                                                                                           Page 3 of 3 
10. Copy of Federal Tax Lien(s) (Complete if applicant and taxpayer differ)        Attached             No 
OR list the lien number(s) found near the top right corner on the lien document(s) (if known) 

11. Copy of the proposed loan agreement (if available)                             Attached             No 
AND 
Describe how subordination is in the best interests of the United States: 

12. Copy of a current title report (required for subordination)                    Attached             No 
OR 
List encumbrances with seniority over the Federal Tax Lien.  Include name and address of the holder; description of 
the encumbrance, e.g., mortgage, state lien, etc.; date of agreement; original loan amount and interest rate; amount 
due at time of application; and family relationship, if applicable. Include any home equity line of credit (HELOCs) 
advances beginning the 46th day after the NFTL was filed, through the date you submit your application, and include 
expected advances through the date the certificate will be issued. (Attach additional sheets as needed): 

13. Copy of proposed closing statement (aka HUD-1)                                 Attached             No 
OR 
Itemize all proposed costs, commissions, and expenses of any transfer or sale associated with property (Attach 
additional sheets as needed): 

14. Additional information that may have a bearing on this request, 
                                                                                   Yes Yes Yes No No No 
such as pending litigation, explanations of unusual situations, etc., 
is attached for consideration 

15. Declaration 
Under penalties of perjury, I declare that I have examined this application, including any accompanying schedules, 
exhibits, affidavits, and statements and to the best of my knowledge and belief it is true, correct and complete. 

                                   Signature/Title                                             Date 

                                   Signature/Title                                             Date 

Catalog Number 54726H                              www.irs.gov                                 Form 14134 (Rev. 06-2010)

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