You may appeal an erroneous tax lien by filing an administrative appeal with the IRS Office of Appeals by a Collection Appeal (CAP), although you cannot use this administrative appeal to decide the underlying tax liability. Erroneous tax liens commonly occur when:
A tax lien was filed after the tax liability was paid, or the taxpayer was in bankruptcy, or
An examination assessment was improperly made; or
The statute of limitations for IRS collections has expired