How to Fill Out and Submit Form 14134: Legal Basis, Filing, and Denials

To fill out Form 14134, choose which subsection of IRC 6325(d) supports your request, gather a current title report and the proposed loan terms, complete every field on the form (entering “N/A” where a question doesn’t apply), and mail or fax the package to the IRS Advisory office in Florence, Kentucky at least 45 days before your closing date. The form is the Application for Certificate of Subordination of Federal Tax Lien, and the IRS charges no fee to process it.¹ The certificate itself (Form 2081) is issued by the IRS after it approves your application.

Pick Your Legal Basis Before You Start

Form 14134 asks you to select the subsection of IRC 6325(d) you’re applying under, and that choice controls what evidence you need to attach. Get it right up front or you’ll assemble the wrong package.

Section 6325(d)(1) — payment to the IRS. You pay the government an amount equal to the lien interest being subordinated. If the lien covers $50,000 and you need a new lender in first position for $50,000, the IRS receives that amount at closing. Because the government is made whole immediately, the review involves less scrutiny.
Section 6325(d)(2) — facilitating collection. No immediate payment. You have to show that stepping the IRS back in priority will ultimately increase what the government collects, for example by lowering your monthly mortgage payment enough to free up cash for installment payments on the tax debt.

The IRS evaluates 6325(d)(2) requests the way a private creditor would look at a risky modification. The Internal Revenue Manual calls this the “ordinary, prudent businessman” standard.³ If the numbers don’t show the government coming out ahead, the request fails.

One boundary matters here. Subordination lets a new lender take priority so you can refinance, but it does not cover cash-out transactions where you pocket equity. If you need to pull cash from a home equity loan or cash-out refinance, the right form is 14135 (lien discharge), a separate process with different requirements.

Documents to Gather First

Your application needs to show a complete financial picture of the property, the existing lien, and the new loan. Missing paperwork is a common reason applications stall.

Current title report. Order this from a title company. It lists every existing encumbrance and its priority. Form 14134 requires you to attach the report or list all encumbrances senior to the federal tax lien.¹
Legal description of the property. Attach a legible copy of the deed or title showing the full legal description, not just the street address.
Proposed loan agreement. Include the new lender’s loan terms if available. This lets the IRS evaluate whether the financing genuinely improves your position.
Copy of the Notice of Federal Tax Lien. Required if you are not the taxpayer named on the lien (for example, a third-party property owner).
Authorization forms. If someone is applying on your behalf, include a signed Form 2848 (Power of Attorney) or Form 8821 (Tax Information Authorization).

A professional appraisal is not required. Form 14134 says so on its face.¹ If you’re applying under 6325(d)(2), though, a credible valuation strengthens the argument that the government’s collection position improves, so consider getting one anyway.

Filling In the Form

Download the current version of Form 14134 from IRS.gov. Complete every field. Where a question doesn’t apply, write “N/A” rather than leaving it blank.

Taxpayer Information

Enter your name and address exactly as they appear on the Notice of Federal Tax Lien. Provide the last four digits of your Social Security number, or your full Employer Identification Number, as shown on the notice. If the liability is joint, include the secondary SSN.⁴

Property and Legal Basis

Identify the type of property (real estate, personal property, or both) and attach the deed or title with the legal description. Then check the box for the 6325(d) subsection you’re using. Under 6325(d)(1), document the payment amount. Under 6325(d)(2), attach a signed, dated statement explaining how the subordination increases what the IRS can ultimately collect and how it makes collection easier.

The Narrative Statement for 6325(d)(2)

This is where most applications succeed or fail. Connect the dots in numbers. State your current monthly obligations, how the new loan changes them, and how much additional cash flow becomes available for tax payments. Vague language about improving financial stability will not carry the application. The IRS wants a concrete dollar-and-cents explanation. Attach the proposed loan terms and any supporting financial documents.

Where to Send It, and When

Subordination applications go to a single centralized office, not to a local IRS office or regional advisory group. Mail the completed Form 14134 and all attachments to:

IRS Advisory Consolidated Receipts
7940 Kentucky Drive, Stop 2850F
Florence, KY 41042

You can also fax the package to 844-201-8382, or submit it electronically through your IRS Online Account at IRS.gov.⁵

Send the application at least 45 days before your planned closing. Publication 784 recommends that lead time to allow for review, a determination, notification, and preparation of the certificate.⁴ Wait until two weeks before closing and the IRS is unlikely to meet your lender’s schedule.

After You Submit

An IRS specialist reviews the application to confirm you chose the correct subsection and that your documentation supports the request. The specialist may contact you to clarify details, request additional financial information, or explain why a different subsection might apply. If the IRS disagrees with your selection, you’ll get a written explanation.⁴

When the IRS approves the request, it issues the certificate. Recording it is your job. Take the certificate to the county recorder or clerk where the property sits and file it there. The Internal Revenue Manual places that responsibility on the applicant unless the local recording agency accepts documents only from the IRS itself.³ Recording fees vary by county but generally fall between $10 and $80. Until the certificate is recorded, the new lender’s priority isn’t legally established in the public record.

If the Application Is Denied

Common denial reasons include incomplete documentation, failure to show that collection will be facilitated under 6325(d)(2), choosing the wrong subsection, and a payment amount that doesn’t match the subordinated interest under 6325(d)(1). The IRS will explain its reasoning in writing.

You can appeal through the Collection Appeals Program, but the deadlines are short and measured in business days:

Ask to speak with the collection employee’s manager first. A manager conference is required before you can file a formal appeal.
If that conference doesn’t resolve the disagreement, notify the collection office within two business days that you plan to submit Form 9423 (Collection Appeal Request).
Form 9423 must be received or postmarked within three business days of the manager conference. Send it to the collection office involved in the lien action.

⁶

If you asked for a manager conference and no manager contacted you within two business days, you can file Form 9423 directly. In that case it must be received or postmarked within four business days of your original conference request. On the form, check the box for the collection action you disagree with, explain why, and propose your own solution for resolving the tax liability. Weekends and federal holidays do not count toward these deadlines.

1
Internal Revenue Service. Application for Certificate of Subordination of Federal Tax Lien
2
Office of the Law Revision Counsel. 26 USC 6325 – Release of Lien or Discharge of Property
3
Internal Revenue Service. 5.12.10 Lien Related Certificates
4
Internal Revenue Service. Publication 784 – How to Apply for a Certificate of Subordination of Federal Tax Lien
5
Internal Revenue Service. Collection Advisory Offices
6
Internal Revenue Service. Collection Appeal Request