Publication 784 (Rev. 12-2022) Catalog Number 46756T Department of the Treasury Internal Revenue Services www.irs.gov
How to Apply for a
Certificate of Subordination of Federal Tax Lien
A Certicate of Subordination under Internal Revenue Code
Section 6325(d)(1) and 6325(d)(2) allows a named creditor to
move their junior creditor position ahead of the United States’
position for the property named in the certicate. For How to
Apply for a Certicate of Subordination of Federal Estate Tax
Lien Under Section 6325(d)(3) of the Internal Revenue Code use
Publication 1153.
1. Complete Form 14134, Application for Certificate of
Subordination of Federal Tax Lien, attached with this
publication.
2. Mail the completed Form 14134 and the appropriate
attachments to:
IRS Advisory Consolidated Receipts
7940 Kentucky Drive, Stop 2850F
Florence, KY 41042
(Refer to Publication 4235, Collection Advisory Group
Addresses, for additional contact information.)
If you have any questions, contact the Advisory Consolidated
Receipts Ofce at 859-594-6090.
If you want to know how much you owe in order to pay the
lien(s) in full, call 1-800-913-6050, visit the nearest Taxpayer
Assistance Center, or contact the revenue ofcer assigned to
your case.
Important!
Please submit your application at least 45 days before the
transaction date that the certicate of subordination is needed.
Doing so will allow sufcient time for review, determination,
notication and the furnishing of any applicable documents by
the transaction date.
Information Required on the Application
Section 1 - Taxpayer Information
1. Enter the name and address of the individual(s) or business
as it appears on the Notice(s) of Federal Tax Lien (NFTL). A
second name line is provided if needed.
2. Enter, if known, the last 4 digits of the social security
number (SSN) or full employer identication number as it
appears on the NFTL.
3. Enter, if known and if applicable, the last 4 digits of any
spousal SSN (secondary SSN) associated with the tax debt
listed on the NFTL.
4. Provide a daytime phone number and a fax number.
Section 2 - Applicant Information
1. Check the box on the rst line of Section 2 if you are both
the taxpayer and the applicant. If you are not the taxpayer,
attach a copy of the NFTL.
2. If you have checked the box indicating that you are the
taxpayer and your information is the same as listed on the
NFTL, enter “same as taxpayer” on the name line.
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
Notice of Federal Tax Lien, enter your name (include any
name changes), current address, daytime phone number
and fax number.
4. If you are not the taxpayer, enter in the box next to “Name”
your relationship to the taxpayer (e.g. parent, uncle, sister,
no relation, etc).
Section 3 - Property Owner
1. Check the box on the rst line of Section 3 if you are both
the property owner and the applicant.
2. Enter the name of the property owner. Or if you have
checked the box indicating you are both the applicant and
the property owner, enter, “same as applicant”.
3. Enter the property owner’s relationship to the taxpayer (e.g.
taxpayer, parent, no relation, etc.).
Section 4 - Attorney/Representative Information
This section is used to list the taxpayer’s representative or a
representative of a party other than the taxpayer, such as the
lender, needing to receive information from the IRS. However,
you do not need a representative to request discharge of the
federal tax lien.
1. Check the box on the rst line of Section 4 if you are
attaching a Form 8821 (Tax Information Authority) or Form
2848 (Power of Attorney) with your application. If you
are attaching one of these forms, please make sure it is
completely lled out, signed, and dated. You must provide
one of these forms if the representative represents an
interest other than the taxpayer.
2. Enter the name, address, phone number, and fax number
of your representative in this action. The IRS will work with
you and your representative to process your application.
Or enter “NA” on the name line if you are not using a
representative.
3. Enter whose interest the representative represents (e.g.
taxpayer, lender, title company, etc.). This allows the IRS
to determine what information can be shared with the
representative.
Section 5 – Lender/Finance Company Information
1. Enter the company name, contact name, phone number,
and fax number for the lender you are requesting the
United States subordinate its interest to.
2. Enter the type of transaction. For example, a loan
consolidation or renance often prompts a subordination
request.
Section 6 – Monetary Information
1. Enter the amount of your existing or outstanding nancing.
2. Enter the amount of new nancing you are seeking.
3. Enter the amount anticipated being paid toward the United
States’ interest (For applications requested under 6325(d)
(1) only).
Publication 784 (Rev. 12-2022) Catalog Number 46756T Department of the Treasury Internal Revenue Services www.irs.gov
Section 7 - Basis for Subordination
A subordination may be granted under Internal Revenue Code
(IRC) 6325(d)(1) or 6325(d)(2). Review the information below
and select the section which best applies to your subordination
request. If the IRS does not agree with your selection after its
review, an explanation of the decision will be provided.
6325(b)(1) – a subordination may be issued under this section
if you pay an amount equal to the lien or interest to which
the certicate subordinates the lien of the United States. The
following example uses an 80% loan to value and a 3% closing
cost to nancing ratio.
Example
Current/New Original
Fair Market Value $200,000 N/A
Renance $160,000 $145,000
Closing Costs $4,800 N/A
United States Interest $10,200 N/A
In this example the United States’ interest is the equity
you obtain from your renanced loan after paying off the
existing loan of $145,000 and paying the closing costs to
obtain the loan. ($200,000 property value x 80% loan to
value ratio = $160,000 renance loan amount. $160,000 -
$145,000 loan payoff = $15,000 potential equity. $160,000
x 3% = $4800 closing costs to obtain the loan. $15,000
potential equity - $4,800 closing costs = $10,200) The
IRS would ask for $10,200 in return for the United States
subordinating its interest to the renanced loan. The lien
remains on the property but the renanced loan has priority
over the lien.
4. 6325(d)(2) – a subordination may be issued under this
section if the IRS determines that the issuance of the
certicate will increase the amount the government realizes
and make collection of the tax liability easier. This might
involve a renance to a lower interest rate which would,
if the subordination were granted, allow a larger monthly
repayment rate on the tax liability. Or the situation might
be more complex. For example, AAA Auto Sales currently
pays the IRS $2000 per month on a $120,000 tax debt.
Their inventory needs replenishing but their wholesaler is
reluctant to provide added inventory because of the federal
tax lien. AAA requests subordination and provides the IRS
with documentation that an inventory replenishment of 500
cars could allow them to increase their monthly payment
to $3000 as well as increase their pay back rate to bi-
weekly. In this example the United States’ interest would
be second on the new inventory, if the subordination is
granted.
For applications under section 6325(d)(2), complete and
attach a signed and dated statement describing how the
amount the United States may ultimately realize through
this subordination will increase and how collection will be
facilitated by the subordination.
5. 6325(d)(3) – Questions and applications for this
sectionrefer to Publication 1153 for instructions.
Section 8 – Description of Property
1. Enter a detailed description of the collateral you will use
for the loan or other nancing. This is the collateral on
which you want the lien interest subordinated to the loan or
nancing. If this is real estate, you must provide the legal
description.
2. When the property is real estate include the type of
property. For example, 3-bedroom house; etc. When the
property is personal property include serial or vehicle
numbers, as appropriate. For example, 2002 Cessna twin
engine airplane, serial number AT919000000000X00; etc.
3. Provide the property’s physical address if it is real estate or
provide the physical address where the property is located,
if it is personal property.
4. Check the appropriate box to indicate whether you
attached a copy of the title or deed to the property
Section 9 – Appraisal and Valuations
1. Check the “Attached” box after “Appraisal” to indicate
whether you have attached an appraisal completed by a
disinterested third party. This is typically a professional
appraisal providing neighborhood analysis; description of
the site; description of the improvements; cost approach;
comparable sales; denition of market value; certication;
contingent and limiting conditions; interior and exterior
photos of the property; exterior photos of comparable
sales used; comparable sales location map; sketch of
subject property showing room layout; ood map and
qualications of the appraiser. This type of appraisal is
not required for a certificate of subordination.
2. Check the appropriate box under the “Or One of the
Following Valuations” section to indicate which type
of property value verication is attached with your
application.
Section 10 − Notices of Federal Tax Lien (NFTLs)
This section is important when the applicant and the taxpayer
are different. If the applicant and the taxpayer are the same, this
section may be skipped.
1. Check the “Attached” box if you have attached copies of
the NFTL with your application.
2. If you checked the “no” box list the System Lien
Identication Number (SLID) found in the top right hand
box of the NFTL document, if available. If you do not have
the numbers enter “unknown” in the rst box.
Section 11 − Proposed loan agreement
1. Check the “attached” box if you have attached the
proposed mortgage contract and describe how
subordination is in the best interests of the United States
2. If you checked the “no” box, describe how subordination is
in the best interests of the United States.
Section 12 − Current Title Report
1. Check the “attached” box if you attached the title report.
This is required for subordination.
2. If you checked the “no” box and the title report is not
attached, use the space provided to list any encumbrances
(liens or claims) against the property and whether those
encumbrances are senior to the United States’ lien interest.
Include the name and address of the holder; description
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
date of agreement; original loan amount and interest rate;
amount due at time of application; and family relationship, if
applicable.
3. If any mortgages listed on your title report are home equity
lines of credit (HELOCs), the NFTL takes priority over
advances made via the HELOC on the 46th day after the
NFTL is led. This means any advances made to you more
than 46 days after the NFTL is led, were made subject to
the NFTL. The advances need to be included in the equity
interest to which the United States attaches. To make an
accurate value determination and to avoid processing
delays with your application, provide documentation on any
HELOC advances from the 46th day after the NFTL was
led, through the date you submit your application, and
include expected advances through the date the certicate
will be issued.
4. Attach a separate sheet titled “Section 12” with the
information in item # 2 and # 3 above if there is not enough
space provided on the form.
Section 13 − Proposed closing statement
1. Check the “attached” box if you attached the proposed
closing statement. This statement is often referred to as a
HUD-1.
2. If you checked the “no” box and you did not attach the
proposed closing statement, use the space provided to
itemize all proposed costs, commissions, and expenses to
renance the property
3. Attach a separate sheet titled “Section 13” with the
information in item # 2 above if there is not enough space
provided on the form.
Section 14 − Additional Information
1. Check the “attached” box if you have attached other
documents relevant to the subordination application. This
could include afdavits or court documents.
2. Check the “no” box if you do not have any additional
documentation.
Section 15 − Declaration
The applicant or their authorized Power of Attorney signs
the application form. You must sign your application under
penalties of perjury attesting to having examined the application,
accompanying schedules or documents, exhibits, afdavits, and
statements and declaring to the best of your knowledge and
belief that the application is true, correct and complete.
Frequently Asked Questions
Q1: When do I make a payment?
The Internal Revenue Code section under which the certicate
of subordination will be issued or granted determines the details
regarding making a payment.
• Subordination under 6325(d)(1) requires a payment, but
do not send a payment with the application. The Advisory
Group Manager will notify you after determining the amount
due and when to send payment.
• Subordination under 6325(d)(2) does not require a payment.
Q2: What is an acceptable form of payment?
Make payments in cash or by the following types of checks:
certied; cashiers; or treasurer’s check. The check must be
drawn on any bank or trust company incorporated under the
laws of the United States, or of any state, or possession of
the United States. Payment can also be made using a United
States postal, bank, express or telegraph money order.
Important! If you pay by personal check, issuance of the
certicate of subordination will be delayed until the bank honors
the check.
Q3: Who makes the decision to issue a Certificate of
Subordination?
In all cases Advisory staff will review and verify the information
provided, determine whether a certicate of subordination
should be issued, and contact you with any questions. Advisory
may contact you, your representative, or any person relative to
the transaction for additional information.
The Advisory Group Manager has the responsibility to review
and approve the determination and let you know the outcome.
If approved, you will receive a conditional commitment letter.
Q4: When will I receive the Certificate of Subordination?
The Internal Revenue Code under which the certicate of
subordination will be issued or granted determines when you
will receive the certicate.
• Under 6325(d)(1), you will receive the certicate upon
receipt of the amount determined to be the interest of the
United States in the property subject to the federal tax lien.
• Under 6325(d)(2), you will receive the certicate after your
application has been investigated and the information
veried. The Advisory Group Manager will notify you of the
decision and provide you with a projected date for mailing
the certicate of subordination.
Q5: What happens if my application is denied?
If your application is denied, you will receive Form 9423,
Collection Appeal Request, and Publication 1660, Collection
Appeal Rights, with an explanation of why your application was
denied.
Privacy and Paperwork Reduction
Act Notice
The Privacy act of 1974 says that when we ask you for
information about yourself, we must rst tell you our legal right
to ask for the information, why we are asking for it, and how it
will be used. We must also tell you what could happen if you do
not provide it and whether or not you must respond under the
law.
We ask for the information on this form to carry out the Internal
Revenue laws of the United States. This information requested
on this form is needed to process your application and to
determine whether the federal tax lien can be subordinated.
You are not required to apply for subordination; however, if you
want the federal tax lien to be subordinated, you are required
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
requires you to provide the requested identication numbers.
Failure to provide this information may delay or prevent
processing your application; providing any false information
may subject you to penalties.
The time needed to complete and le this form will vary
depending on individual circumstances. The estimated burden
for individuals ling this form is approved under OMB control
number 1545-2174. The estimated burden for those who le
this form is shown below.
• 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.
Routine uses of this information include giving it to the
Department of Justice for civil and criminal litigation, and
to cities, states, the District of Columbia, and United States
commonwealths and possessions for use in administering their
tax laws. Advisory may contact you, your representative, or any
person relative to the transaction for additional information.
We may also disclose this information to other countries
under a tax treaty, to federal and state agencies to enforce
federal nontax criminal laws, or to federal law enforcement and
intelligence agencies to combat terrorism.
Form 14134
(June 2010)
Application for Certificate of Subordination of
Federal Tax Lien
Department of the Treasury — Internal Revenue Service
OMB No. 1545-2174
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
Name Continuation
(Individual First, Middle Initial, Last) or (Business d/b/a)
Address (Number, Street, P.O. Box)
Primary Social Security Number
(last 4 digits only)
Secondary Social Security Number
(last 4 digits only)
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
Power of Attorney Form 2848
Yes No
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)
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
third party but it is not required for a subordination)
Attached
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)
No No Yes Yes
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,
such as pending litigation, explanations of unusual situations, etc.,
is attached for consideration
Yes No
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)
