Ezel / IRS Rulings / 201916010
Chief Counsel Advice 201916010 Released April 19, 2019 Advice

Where to look in the IRM before filing a lien on an additional assessment

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This page covers one taxpayer's ruling from 2019, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2019
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

This is a one-paragraph internal email from the Office of Chief Counsel
answering a colleague's question about filing Notices of Federal Tax Lien
(NFTLs) when the government makes an additional assessment against a
taxpayer. The response gives no legal analysis of its own; it simply
points the questioner to the relevant procedures in the Internal Revenue
Manual, specifically IRM 5.12.2.3.2(2), IRM 5.12.2.6, and IRM 5.12.2
generally, and offers to discuss further. Federal tax liens arise under
IRC § 6323, whose UILC subject here is the filing of the lien notice.
Someone would care because the timing and mechanics of refiling or adding
a lien after a new assessment affect the government's priority against
other creditors.

Ruling snapshot

  • Question: Where in the IRM are the procedures for filing NFTLs on additional assessments?
  • Outcome: Advice given (pointer to IRM sections; no ruling)
  • Key authorities: IRC § 6323; IRM 5.12.2 (5.12.2.3.2(2), 5.12.2.6)

Full text (IRS public release)

ID: CCA_2019032714050352
UILC: 6323.01-00

Number: 201916010
Release Date: 4/19/2019
From:
Sent: Wednesday, March 27, 2019 2:05:03 PM
To:
Cc:
Bcc:
Subject: lien filing question

Regarding filing NFTLs on additional assessments, take a look at IRM 5.12.2.3.2(2),
IRM 5.12.2.6 and elsewhere in IRM 5.12.2.

If you would like to talk about this further, please contact me.

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