Alter-Ego Lien
A notice of lien filed against property held by an entity the IRS treats as indistinguishable from the taxpayer. It is appealable under the Collection Appeals Program.
Full Definition
A federal tax lien attaches to the taxpayer's property. An alter-ego lien is a notice of lien filed against property held in the name of someone or something else — commonly a company — on the basis that the IRS treats that entity as indistinguishable from the taxpayer.
The one thing worth knowing about it here is that it can be appealed. The instructions to Form 9423 list "the filing of a notice of lien against an alter-ego or nominee's property" among the actions a taxpayer, or a third party whose property is subject to a collection action, may appeal under the Collection Appeals Program.
That third-party clause is the important part. The entity whose property has been encumbered has a route of its own, and does not have to wait for the taxpayer to act.
What the test for alter-ego status is, and what evidence establishes it, is not described here. The IRS does not publish that in taxpayer-facing material, and the determination turns on state law as much as on federal tax law.
What to do next
If a lien has been filed against property you hold and you are not the taxpayer named on it, Form 9423 is the appeal route the IRS publishes, and the instructions to that form set out the deadlines — which are measured in business days.
What this page does not say
- The IRS does not publish, in taxpayer-facing material, the test it applies to decide that an entity is a taxpayer's alter ego. This page names the appeal route and stops there rather than describing a standard from a secondary source.
Sources
- Form 9423, Collection Appeal Request (Rev. 2-2020) — instructions — Internal Revenue Service, retrieved 2026-08-20
- Understanding a federal tax lien — Internal Revenue Service, retrieved 2026-08-20
Last reviewed 2026-08-21 by Tax Resolution Clarity editorial.
Sourced to primary IRS materials and editorially reviewed. Not reviewed by a tax professional. Not tax advice.
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Where to go next
The IRS publishes the rules this page describes. Your own notice governs your dates.