Lien Notice CDP Window
The hearing clock after a lien filing runs in two stages: five business days for the IRS to notify, then thirty days for you.
Full Definition
When the IRS files a Notice of Federal Tax Lien, the Collection Due Process clock does not start on the filing date. It runs in two stages, and Publication 1660 sets both out.
First, the IRS's obligation: "The IRS is required to notify you the first time a Notice of Federal Tax Lien is filed for each tax and period. The IRS must notify you within 5 business days after the lien filing." That notice may be mailed, given to you, or left at your home or office.
Then yours: "You then have 30 days, after that 5-day period, to request a hearing with Appeals."
The publication adds the sentence that makes the arithmetic unnecessary: "The lien notice you receive will indicate the date this 30-day period expires."
Use the printed date. The two-stage structure is worth understanding because it explains why the deadline on the notice is not thirty days from the filing — but it is not a computation to perform yourself, and the same publication says so.
What to do next
Find the expiry date printed on the lien notice. Publication 1660 states the notice indicates the date the 30-day period expires, which makes it the authority over any calculation from the filing date.
Sources
- Publication 1660, Collection Appeal Rights — Internal Revenue Service, retrieved 2026-08-18
- 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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Related Terms
Where to go next
The IRS publishes the rules this page describes. Your own notice governs your dates.