Nominee Lien
A notice of lien filed against property held in someone else's name for the taxpayer's benefit. Like an alter-ego lien, it is appealable under CAP.
Full Definition
A nominee lien is a notice of federal tax lien filed against property that is held in another person's name but that the IRS treats as belonging, in substance, to the taxpayer.
The difference from an alter-ego lien is one of framing rather than procedure: an alter-ego claim says the entity IS the taxpayer, a nominee claim says the holder holds FOR the taxpayer. The IRS groups them together for appeal purposes.
The instructions to Form 9423 list "the filing of a notice of lien against an alter-ego or nominee's property" among the actions appealable under the Collection Appeals Program, and state that a third party whose property is subject to a collection action may appeal — not only the taxpayer.
The test for nominee status is not set out here. The IRS does not publish it in taxpayer-facing material.
What to do next
If property you hold has been subjected to a lien on a nominee theory, Form 9423 is the published appeal route and its instructions carry the deadlines. A certificate of non-attachment is the separate route where the issue is that the lien does not attach to you at all.
What this page does not say
- The IRS does not publish the nominee test in taxpayer-facing material. This page names the appeal route rather than describing a standard it cannot 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.