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 

for a certificate of subordination of Federal Estate tax lien, 

a typewritten request will be considered an application. 

Submit your typewritten request and all accompanying 

documents to: 

Address application to: 

Internal Revenue Service 

Advisory Estate Tax Lien Group 


55 South Market St. Mail Stop 5350 


San Jose, CA 95113-2324 


Attn: Group Manager 


E-fax number: 877-477-9243 

Give date of application: 

Please give the name and address of the person applying, 

under section 6325(d) of the Internal Revenue Code, for a 

certificate of subordination. Give the name and address of 

the decedent at the time of death and describe the property 

as follows: 

1.	 Give a detailed description, including the location, of the 

property for which you are requesting the certificate of 

subordination. If real property is involved, use the description 

contained in the title or deed to the property, and the complete 

address (street, city, State, and ZIP code). 

2.	 Attach a copy of each notice of Federal estate tax lien, or 

furnish the following information as it appears on each filed 

notice of Federal tax lien: 

a.	 The name of the Internal Revenue Area; 

b.	 The name and address of the taxpayer against whom the notice 

was filed; 

c.	 Serial number shown on the lien; 

d.	 Taxpayer’s identification number shown on the lien; 

e.	 The date and place the notice was filed; 

f.	 In lieu of the above, a preliminary title report may be substituted 

listing the required information. 

3.	 Describe the encumbrance to which the Federal estate tax lien 

is to be subordinated, including: 

a.	 The present or proposed amount of the encumbrance, or both; 

b.	 The nature of the encumbrance (such as mortgage, assignment, 

etc.); 

c.	 The date the transaction is to be completed. 

4.	 List the encumbrances (or attach a copy of the instrument that 

created each encumbrance) on all the property subject to the 

estate tax lien, that you believe has priority over the estate tax 

lien. For each encumbrance show: 

a.	 The name and address of the holder; 

b.	 A description of the encumbrance; 

c.	 The date of the agreement; 

d.	 The date and place of any recording; 

e.	 The original principal amount and the interest rate; 

f.	 The amount due, if known, as of the date of the application for 

certificate of subordination (show costs and accrued interest 

separately); 

g.	 Your family relationship, if any, to the holder(s) of any other 

encumbrances on the property. 

Also show the following: 

5.	 An estimate of the fair market value of the property for which 

you would like a certificate of subordination, the basis of this 

estimate, and a separate estimate of any remaining property 

subject to the estate tax lien. 

6.	 The name address, and social security numbers of the 

decedent’s estate or any qualified heir(s) of property subject to 

the notice of Federal estate tax lien. 

7.	 If the applicant or the applicant’s legal representative is not 

the agent designated by the estate, executor or the qualified 

heir(s) for dealings with Internal Revenue Service regarding 

the property, submit a written authorization for the applicant or 

representative to apply for a subordination of the estate tax lien. 

8.	 The purpose of the loan for which the subordination is sought. 

9.	 The amount of money to be loaned to the applicant, the terms 

of repayment, and the exact name of address of the lender. 

Please include the name and telephone number of a contact 

person in the lender’s office. 

10. A daytime telephone number where you can be reached. 

11. The name, address, and telephone number of your attorney or 

other legal representative. 

12. Make the following declaration over your signature and title: 

“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.” 

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