Part 5. Collecting Process

Chapter 12. Federal Tax Liens

Section 6. Procedures for Lien Processing (Cont. 1)

5.12.6  Procedures for Lien Processing (Cont. 1)

5.12.6.4 
Collection Due Process (RRA) Notices

5.12.6.4.6  (11-30-2007)
Other CDP Notices

  1. There are four other notices issued that relate to collection due process. These notices explain whether the taxpayer is entitled to a CDP hearing.

    1. L3171, Notice of Federal Tax Lien Filing - issued when an additional NFTL has been filed in another location and the taxpayer has already received notice of their right to a hearing. ALS systemically generates this notice. (CPS prints and mails this notice.)

    2. L3177, Notice of Federal Tax Lien Filing - Nominees or Alter-Ego - issued in nominee and alter-ego situations. ALS does not systemically generate this notice.

    3. L3886, Notice to Taxpayer of Nominee/Alter Ego Federal Tax Lien Filing - issued to taxpayers who are identified as having property in the name of a nominee or alter-ego. ALS does not systemically generate this notice.

    4. L3527, Notice of Federal Tax Lien Filing - Child Support Obligation - issued when a lien is filed on a taxpayer with outstanding child support obligations. ALS does not systemically generate this notice.

  2. The employee requesting the NFTL is responsible for ensuring that the appropriate notice is prepared and mailed.

  3. L3886 must meet the 5 business day mail requirement.

  4. There is no requirement to send the remaining letters using certified mail.

  5. Systemically generated CDP notices are printed and mailed from CPS.

  6. CLU is not responsible for printing or mailing notices not systemically generated.

  7. CLU procedures are found in IRM 5.19.12.

5.12.6.4.7  (11-30-2007)
Maintaining Postal Registers

  1. Lien CDP notices will be sent certified mail unless the taxpayer has a foreign address. If the taxpayer has a foreign address, the notice will be sent registered mail.

  2. ALS creates United Stated Postal Service (USPS) mail registers when the L3172 is printed. The form lists the SLID, taxpayer name and address, certified mail cost, and certified mail number for each notice being mailed.

  3. Legible receipted (date stamped by the U.S. Post Office) copies of registers are maintained by the CLU.

  4. Registers are retained in date order by year.

  5. In cases where the post office (USPS Form 3800) certified mail receipt or (USPS Form 3650) registered mail receipt, is used, the CLU will retain the stamped receipted copy.

  6. Forms will be retained in date order by year and taxpayer name.

  7. Registers and receipts for outgoing registered and certified mail may be destroyed 10 years after the end of the processing year.

  8. CLU procedures are found in IRM 5.19.12.

5.12.6.5  (07-16-2010)
Processing Lien Related Certificates

  1. The ALS approval queue is the mechanism used by the CLU to generate documents where employees, with the delegated authority, have determined that the issuance of a lien related certificate is appropriate.

  2. Functional managers may authorize certificate input by lower graded employees who have ALS experience or training. These managers are responsible for the accuracy of the information input. Functional managers should have sufficient internal controls to approve the input of the certificate prior to the actual input. An ICS or AIS history entry by the manager meets this requirement.

  3. ALS generates the following certificates related to the NFTL.

    1. Form 668(Z), Certificate of Release of Federal Tax Lien,

    2. Form 12474, Revocation of Certificate of Release of Federal Tax Lien,

    3. Form 12474-A, Revocation of Certificate of Release of Federal Tax Lien,

    4. Form 10916(c), Withdrawal of Filed Notice of Federal Tax Lien.

  4. Certificate issuance has been approved prior to ALS input. Therefore, documents will be generated and mailed without contacting the functional manager.

  5. Functions requesting the preparation of the above referenced certificates by CLU must complete Form 13794.

  6. Lien certificate recording data generally will be added to the ALS history, within 5 days of receipt, but not later than 10 days of receipt.

  7. These procedures also apply to the issuance of partial release and withdrawal certificates. Requesting functions will prepare partial withdrawal or release certificates and refer to CLU as an attachment to Form 13794.

    Note:

    Withdrawals must be approved by an Advisory or Insolvency Group Manager prior to being input to ALS or issued. See Delegation Order 5-4 found in IRM 1.2.44.4(41-43)

  8. Whenever an NFTL is released, TC 583 must be input with a definer code. Manual and systemic input is available.

    1. DC 1 - released

    2. DC 2 - withdrawal due to administrative error

    3. DC 3 - withdrawal due to collection due process appeal rights

    4. DC 4 - reversal

    5. DC 5 - self-released (statute expiration).

5.12.6.5.1  (07-16-2010)
Certificate of Release

  1. IRC 6325 requires that a certificate of release (Form 668-Z) be issued within 30 days of a determination by the Service that the tax liability is satisfied or becomes legally unenforceable.

  2. Generally, the certificate of release is systemically generated from data downloaded to the ALS from master file. In some cases, the release can be requested manually. Examples of appropriate times to manually release liens are:

    1. taxpayer paying with certified funds;

    2. pending property transactions (the certificate is provided upon receipt of payment);

    3. liability discharged in bankruptcy;

      Note:

      It is not appropriate to release a NFTL on a discharged liability if the pre-petition NFTL attached to exempt, abandoned, or excluded property against which the Service might enforce its in rem property interest. Also, a NFTL for discharged tax liabilities should not be released until after the Service receives its distribution in the bankruptcy case.

    4. OIC is accepted and the offered amount is full paid.

  3. In the above referenced examples, issue an immediate release, if requested. Such requests may be faxed or secure e-mailed to CLU. Highlight " immediate release" at the top of the request.

  4. When full payment is made by personal check, the statutory 30 day requirement to release the NFTL does not begin until the funds are received. The Secretary has determined that 15 calendar days may lapse after receipt before the 30 day release requirement begins.

  5. If a credit line check is received, the 30 day release period will begin 15 calendar days after receipt. However, if the credit line check is converted into certified funds, issue an immediate release. Additional procedures are found in IRM 5.12.6.5.1.5.

  6. Provide taxpayers with a certificate of release in cases where the liability is satisfied and the taxpayer is paying with certified funds.

  7. Issue a certificate of release if the collection statute has expired, and the taxpayer requests a release.

  8. Releases are printed and mailed twice weekly.

    Note:

    Normally very few days remain on the 30-day period when releases are systemically generated. Prompt processing by the lien unit is required.

5.12.6.5.1.1  (07-16-2010)
Department of Justice or Court Ordered Requests for Issuance of Certificates of Release

  1. Occasionally, it is necessary for the IRS to issue certificates of release based on court decisions or at the request of the Department of Justice.

  2. These requests will be acknowledged and the release will be prepared and issued immediately upon receipt.

  3. The requesting employee will provide all pertinent information to prepare the release, including the taxpayer's current address.

  4. Follow instructions provided by the requesting employee for recording the release. It may be necessary for the employee to hand carry the document to the recording office. The employee should pay the recording fee and be reimbursed through the travel voucher system. the filing fee exceeds normal costs and the recorder accepts the billing voucher (Form 3982), provide the recorder Form 3982 with instructions to fax it to the CLU so that it may be included in their next EFT.

  5. A history must be added to ALS by the CLU that the certificate of release was hand carried, include the date the certificate was provided to the employee, and the requesting employee's name.

  6. When the release is hand carried to the recording official, the requesting employee will forward a copy of the certificate of release with the recording data to the CLU for ALS input.

5.12.6.5.1.2  (07-16-2010)
Issuing a Certificate of Release When Receiving Electronic and Credit Card Payments

  1. DO NOT issue an immediate release when credit or debit cards are used to full pay the tax liability. It is unlikely that a release will be requested from a credit or debit card payment because the Service may accept such payments only within three years after assessment. See IRM 5.14.10.5. Credit and debit cards are barred for satisfaction of liabilities because of the possibility of chargeback of such payments over a period of months. Certificates of release will be issued systemically when the account is fully satisfied (Status12) by use of the ALS/IDRS module satisfaction process.

  2. If a debit or credit card is accepted to satisfy a tax liability and a request for a release is received, the lien may not be released until the period for chargeback has run. The maximum period for chargeback is 120 days for payment by credit card under 15 U.S.C. § 1666, and 100 days for payment by debit card under 15 U.S.C. § 1693f. For general information regarding payment of tax liabilities with credit and debit cards by individuals, see IRM 5.14.10.5.

  3. Issue an immediate certificate of release when full payment of the liability is made by electronic funds transfer (EFT). These payments become irrevocable in a short period of time.

5.12.6.5.1.3  (07-16-2010)
Certificates of Release Requested by the Taxpayer Advocate Service or Appeals Offices

  1. Neither the Taxpayer Advocate Service (TAS) nor Appeals have the authority to release Federal Tax Liens.

    1. TAS must use an Operations Assistance Request (OAR) which is Form 12412 to request the IRS release a lien. Before issuance of an OAR, TAS should establish that IRC lien release statutory requirements have been met.

    2. Appeals uses Request for Release, Partial Release, or Withdrawal of Notice of Federal Tax Lien which is Form 13794 for their requests. Before requesting a line release, Appeals should establish that IRC lien release statutory requirements have been met.

  2. If the TAS is requesting a certificate of release via an OAR for a pending property settlement, and the TAS has determined there is a hardship situation, TAS should verify prior to the issuance of an OAR that the tax liability will be satisfied:

    1. through imminent refinancing with the settlement agency;

    2. through imminent closing of the sale of the property;

    3. by ensuring the government will receive its interest in the property; or

    4. by the liability being unenforceable.

  3. The TAS OAR or Appeals Form 13794 are faxed to the FORT with Form 3210.

  4. The FORT will acknowledge receipt and provide requested documents within time frames established with TAS and Appeals. Such requests will be acknowledged within one business day but not later than three business days.

5.12.6.5.1.4  (07-16-2010)
Partial Release

  1. Circumstances sometimes dictate that a partial release of the NFTL is necessary.

  2. Forward requests for partial releases to CLU, if you do not have access to the ALS lien release option.

  3. CLU generally inputs requests within five days of receipt of the request.

  4. The requesting employee must provide the appropriate entity, TIN (make sure this is the TIN of the person no longer liable for the tax liability), tax type, tax period, unpaid balance of assessment, filing location, etc., to complete the certificate of release.

  5. Provide the reason the partial release is being requested. For example, there is a joint account and only one taxpayer requested an offer in compromise and the offer was accepted. The agreed amount has been paid and the tax examiner is requesting release of the federal tax lien.

  6. A partial release will be generated when there are multiple tax periods and the taxpayer requests a release for a specific tax period that has been fully satisfied or has become legally unenforceable. However, standard practice should be to issue a release after all modules are satisfied.

  7. A partial lien release will be prepared using ALS. The release (Form 668(Z)) is prepared with a standardized paragraph (across the face of the form) explaining the reason for release, identifying the taxpayer and the tax period(s) satisfied.

  8. CLU procedures are found in IRM 5.19.12

5.12.6.5.1.5  (07-16-2010)
Taxpayer Request for Release

  1. Normally, requests for a certificate of release must be in writing and signed by the taxpayers.

  2. Requests received by fax may be accepted if contact has been made by phone, or in person and the taxpayer history file is documented with the date of contact and a notation is made that the taxpayer wishes to send the request by fax.

  3. Complete requests within 5 days of receipt, except when taxpayers are waiting on the certificate. In those cases, prepare the certificate of release immediately upon receipt of certified funds.

  4. Occasionally, taxpayers request a certificate of release (Form 668(Z)) when the language on the NFTL has self-released both the NFTL and the FTL. Check IDRS for the account status.

    If the liability and then
    collection statute has expired a request for a copy of the certificate of release is received provide the taxpayer or the representative with a copy of the certificate.
    is full paid there is a credit balance or the balance is zero issue a certificate of release.

    Note:

    Notify your manager that a credit balance exists or the account balance is zero and the taxpayer has no other liability.
    is not full paid there is a balance inform the taxpayer that there is a balance due on the account and that a certificate of release will not be issued.

    Note:

    Refer the request to the appropriate function based on the status of the account. Accounts that are not in status 22, 26, 71, or 72 will be resolved by referring the taxpayer to the toll free number for assistance or in hardship situations to the nearest local Taxpayer Advocate Service office.

    Refer taxpayers to the TAS (see IRM Part 13, Taxpayer Advocate Service) when the contact meets TAS criteria (see IRM 13.1.7, TAS Case Criteria ) and you can't resolve the taxpayer's issue the same day. The definition of "same day" is within 24 hours. "Same day" cases include cases you can completely resolve in 24 hours, as well as cases in which you have taken steps within 24 hours to begin resolving the taxpayer's issue. Do not refer " same day" cases to TAS unless the taxpayer asks to be transferred to TAS "and" the case meets TAS criteria. Refer to IRM 13.1.7.4, "Same-Day Resolution by Operations" . When you refer cases to TAS use Form 911, Request for Taxpayer Advocate Service Assistance (and Application for Taxpayer Assistance Order), and forward to TAS.

  5. Taxpayers are provided a copy of the certificate of release at their request when the tax period is full paid. This procedure also applies to requests received by the CLU.

  6. Inform the taxpayer that the IRS does not retain recorded copies of the certificate of release. Recorded copies can only be obtained from the recording official.

  7. When the taxpayer makes us aware that a copy of the lien cannot be found in the recording office, request that the taxpayer contact the credit reporting service to obtain information regarding the lien filing.

  8. Upon receipt, enter the lien information into the database (creating a "not to be filed lien" , if necessary) using SCreate, then generate the release.

  9. Provide the taxpayer with a copy of the certificate of release (Part 1 - Recording Office) and a copy of Notice 48, Release of Federal Tax Lien, if the taxpayer intends to have the release recorded.

  10. Document the ALS history.

  11. CLU procedures are found in IRM 5.19.12.7.6.3.

5.12.6.5.1.6  (07-16-2010)
Taxpayers May Receive Form 3982, Billing Support Voucher (BSV), for Release Recording Fees

  1. If a tax liability has been satisfied and a certificate of release was not received by the recording office, the taxpayer may either pay the recording fee or be provided with a Form 3982, Billing Support Voucher (BSV), to cover recording fees. If the taxpayer is provided Form 3982, instruct them that the recording office needs to fax the billing voucher to the CLU so that the recorder will receive payment in their next EFT.

    Note:

    Some recorders may not accept the BSV. In those cases, the taxpayer must pay recording fees. If the taxpayer wants the release recorded immediately, they must pay the recording fee.

  2. If the request for release is due to bankruptcy or collection statute expiration, provide taxpayers with Notice 48, Release of Federal Tax Lien. The notice informs them of the requirement to pay the recording fee.

  3. If immediate recordation is not required, inform the taxpayer the certificate will be mailed to the recording office.

5.12.6.5.1.7  (11-30-2007)
Lien Release Tracking System

  1. As a means of verifying the date certificates of release leave the IRS, a copy of the billing support voucher that lists any release will be date stamped by the IRS mail room or U. S. Post Office and retained.

  2. Retention of these documents will be the responsibility of the Centralized Lien Unit.

  3. Billing support vouchers will be retained in such a manner as to be easily retrievable, i.e., in date order by year, by state, by recording office.

  4. The retention period is six (6) years, three (3) months.

  5. Billing support vouchers retained to support the recording office invoices meet the requirement in (4) above, if the voucher is appropriately date stamped.

5.12.6.5.1.8  (07-16-2010)
Certificates of Release Not Found in Recording Office

  1. Occasionally the certificate of release cannot be located by the recording office even though ALS shows that the release was issued. Requests for copies of releases are routinely received by CLU from taxpayers or their representatives, but sometimes are received by revenue officers.

  2. The original copy of the certificate of release must be reprinted. These documents should be processed the same day notification is received.

  3. Recording fees will not be posted to the taxpayer's account.

  4. If a taxpayer is waiting on the certificate, inform him/her that he/she can take the copy to the recording office, however, a recording fee must be paid. If the taxpayer elects to record the release, abate the release fee from the taxpayer's account OR provide the taxpayer with a signed copy of Form 3982, Billing Support Voucher for Lien and Certificate Fees, for jurisdictions that accept them. If the taxpayer is provided the Form 3982 for the recording office instruct them that the recorder needs to fax the billing voucher to the CLU so that they may be paid with their next EFT.

  5. Provide the taxpayer with a copy of Notice 48, Release of Federal Tax Lien, when the statute has expired. The taxpayer will be responsible for the recording fee.

  6. Input an ALS history indicating the date and to whom the release was provided.

5.12.6.5.2  (07-16-2010)
Certificate of Revocation

  1. The certificate of revocation is issued when a NFTL has been released or self-released in error which also extinguishes the underlying statutory lien. The revocation reestablishes the statutory lien as of the date the revocation has been both mailed to the taxpayer and filed in the same recording office(s) where the original NFTL(s) filed. See IRM 5.12.3 for more information on revocations. There are two versions of the certificate of revocation.

    1. Form 12474 - issued to revoke a release that was requested in error.

    2. Form 12474-A - issued when a NFTL was not refiled timely and the collection statute expiration date has not expired.

  2. Approval of revocations, per Delegation Order 5-4 found in IRM 1.2.44.4(23-25), is delegated to Advisory and Insolvency Group Managers (AIQ). Employees working lien payoffs or related issues that discover an erroneous release should request revocation by providing necessary information to AIQ.

  3. The employee researches the liabilities shown on the erroneously released NFTL to determine if a revocation of the release is appropriate.

    Note:

    Because of the effect of the release on the statutory lien, revocations should be requested unless legally precluded. In addition to being legally precluded, do not request revocations if, due to the remaining time left on the statute, amount owed on the liability, or other business factors, it would be inappropriate to revoke the release.

    Note:

    Although priority may be lost to competing liens - both those in existence when the federal tax lien was erroneously released, and those coming into existence between the erroneous release date and the revocation/reinstatement date, it is nevertheless important to use the revocation and reinstatement procedures in order to correct the presumptive conclusive extinction of the lien under IRC Section 6325(f)(1)(a), and prevent additional loss of priority when future competing liens arise, especially where significant property interests exist or are reasonably anticipated to come into existence during the life of the extended collection statute.

  4. With the revocation, the employee makes a determination whether a new NFTL should be filed.

    1. See IRM 5.12.2 for lien refiling criteria.

    2. See IRM 1.2.44.4 for delegation orders on who is authorized to make lien determinations.

  5. The employee provides information regarding the erroneous release to AIQ via secure e-mail, fax, or regular mail. The information should include:

    1. The form of the release, i.e., certificate issued or lien self-released.

    2. The reason for the revocation.

    3. The date the certificate of release was recorded and the applicable recording information.

      Note:

      Recording information is not available for self-released liens.

  6. The employee provides necessary information to AIQ for the subsequent filing of a new NFTL.

    1. If multiple federal tax liens were erroneously released on the same taxpayer, revocations must be completed for each released NFTL and filed in each location the erroneously liens were filed to reinstate the underlying statutory lien(s).

    2. The modules for the now reinstated liens can be combined on one NFTL when the new NFTL - following the revocation(s) - is requested. The new NFTL can be filed in the location appropriate for the current status of the case.

    3. If the modules on the now reinstated lien(s) were also on a NFTL filed in another location, a new notice of lien should also be requested for the other location.

  7. AIQ reviews the request, secures additional information as necessary, determines the legality of filing the revocation and new NFTL and makes an approval decision.

    Note:

    Advisory controls the case on ICS under OI case code 148 and maintains a history of the review and decision.

  8. On approved cases, AIQ forwards the request for revocation and new lien filing to CLU for processing. Alternatively, Advisory may input the information to ALS directly following the established process.

  9. Within 5 days of receipt, CLU inputs the revocation to ALS and secures the immediate approval of the revocation in the ALS manager's queue.

    Note:

    If the revocation appears in the ALS manager's queue, CLU may generate certificates of revocation without contacting the functional manager. Functional approval occurred prior to input of the certificate.

  10. CLU adds a history item to ALS:

    1. to show the recording data for the release,

      Note:

      This information must be included on the printed revocation.

    2. to indicate the reason for the revocation, and

    3. to reflect the periods involved, if a partial revocation.

  11. After revocation is approved, CLU inputs the new lien information.

    1. If the taxpayer received a CDP notice for the modules on the previously filed NFTL, the CDP notice should be suppressed from issuance.

    2. If Advisory processes the revocation and new NFTL request instead of sending it to CLU, Advisory must ensure that the revocation is recorded prior to the new NFTL being filed.

  12. It is imperative that the revocation be filed and a copy of the revocation mailed to the taxpayer before the new NFTL is filed. The CLU employee inputting the revocation and new lien will apprise the employee responsible for printing and mailing the documents to the recording office to associate the revocation and new NFTL. Prior to mailing documents, instructions will be attached to the associated documents to advise recording officials to file the revocation before recording the NFTL.

  13. The taxpayer's copy of the notice of revocation will be mailed to the taxpayer by CLU.

  14. When the recorded certificate of revocation is returned, recording information will be added to the ALS history.

5.12.6.5.2.1  (07-16-2010)
Partial Revocations

  1. Issue a partial revocation when:

    1. a release is issued in error on joint liabilities where one party remains liable for the tax;

    2. only some periods listed on the notice of lien are still valid;

    3. a lien is not refiled timely on a specific period on a multiple period lien.

  2. Partial revocations can be completed on ALS.

  3. Partial revocations and the subsequent new lien filing will be processed according to the directions in IRM 5.12.6.5.2, with the exception of the preparation and distribution of the revocation certificate.

  4. The requesting employee may prepare or send the request to CLU to prepare the partial revocation. The IRS Intranet or ICS template versions of Forms 12474 and 12474-A may also be used. The preferred method is using ALS.

    1. The form will be annotated "Partial Revocation" in the box titled. "For Optional Use by Recording Office."

    2. The data on Form 12474 pertaining to the modules/names subject to revocation must match the data on the original NFTL exactly.

  5. If manually prepared, AIQ approves the partial revocation, if appropriate, scans and secure e-mails the completed document to CLU for processing. Revocations created using ALS will go to the manager's queue for approval.

  6. The taxpayer's copy of the partial revocation is forwarded (manual processing only) to the taxpayer by AIQ.

  7. CLU adds the partial revocation to the billing support voucher, associates it with the new NFTL and mails it to the recording official.

5.12.6.5.2.2  (07-16-2010)
Issue a Certificate of Release When Liability is Full Paid After Revocation

  1. When the erroneously released NFTL and FTL is revoked, the filed (and mailed) revocation reinstates the statutory lien. The released " notice" of lien (NFTL) remains ineffective even though the release is revoked. To re-establish priority against IRC 6323 protected creditors, the IRS must file a new NFTL. If the IRS files only a revocation of release, the IRS has available only those administrative and judicial actions available with a statutory lien. There may also be confusion as to the status of the previously released NFTL when the liability is fully satisfied.

    If ... And ... Then ...
    a new NFTL is filed after the revocation a certificate of release is issued when the liability on the NFTL is subsequently satisfied this effectively extinguishes the liens on those modules and no further action is necessary
    a new NFTL is not filed after a revocation is recorded because a certificate of release is not generated when the liability on the revocation (and previously filed NFTL) is subsequently satisfied a manual certificate of release of the original NFTL must be created to resolve the revocation and any questions regarding the original NFTL
    other scenarios are encountered   contact Advisory for the appropriate response

  2. ALS will not allow users to request a release after a revocation has been issued. Manually prepare the certificate of release.

  3. Secure e-mail the release to CLU for processing.

5.12.6.5.3  (07-16-2010)
Certificate of Withdrawal

  1. The Form 10916(c), Withdrawal of Filed Notice of Federal Tax Lien is issued when:

    1. an administrative error has occurred, e.g., a lien filed on a taxpayer during a bankruptcy proceeding.

    2. the taxpayer entered into an installment agreement and the agreement does not provide for the lien filing.

    3. withdrawal will facilitate collection of the tax liability, and

    4. withdrawal is in the best interest of the government and the taxpayer.

  2. Per Delegation Order 5-4 found in IRM 1.2.44.4, Advisory and Insolvency are authorized to approve withdrawal of the NFTL.

  3. The certificate of withdrawal is normally signed by Collection Advisory or Insolvency managers; however, documents generated by ALS will have digitized signatures.

  4. Taxpayers and field personnel will request NFTL withdrawal through Advisory or Insolvency.

  5. Advisory and Insolvency managers may authorize certificate input by lower graded employees who have ALS experience or training. These managers are responsible for the accuracy of the information input. Functional managers should have sufficient internal controls to approve the input of the certificate prior to actual ALS input. An ICS or AIS history entry by the manager meets this requirement.

    Note:

    With managerial approval, the ALS "Bypass Approval" option is available to Advisory and Insolvency employees. This option places documents directly into the ALS print queue. CLU intervention is not required. Managers who opt to use this feature must secure e-mail the names of selected advisors to CLU

  6. The CLU will print the withdrawal and send it to the recording office for recordation.

  7. Employees requesting the issuance of a certificate of withdrawal will expect issuance within five days of forwarding the request to CLU.

  8. The employee requesting the withdrawal will abate the original NFTL TC 360 posted to the taxpayer's account.

5.12.6.5.3.1  (07-16-2010)
Partial Withdrawal

  1. Neither the Internal Revenue Code nor the Treasury Department's Regulations have provisions for issuing a partial withdrawal. However, circumstances may exist that require a partial withdrawal.

  2. Partial withdrawals can be created using ALS (the preferred method) or manually prepared.

  3. Advisory approval is also required for partial withdrawals. Functional employees (revenue officer, tax examiner, OIC specialist, etc.) are responsible for obtaining Advisory approval and preparing the partial withdrawal certificate and obtaining approval. The document must clearly identify (on the face of the document) which taxpayer remains responsible for the liability. Also, the document, if prepared using ALS, will go to the manager's queue for approval.

  4. If manually prepared, attach the approved partial withdrawal to the referral document and secure e-mail the scanned document, fax or mail to the CLU.

  5. The IRS will pay the filing fee.

  6. Do not abate the TC 360 from the liable taxpayer's account.

  7. CLU procedures are found in IRM 5.19.12.

5.12.6.6  (07-16-2010)
Authority to Sign and Generate ALS Documents

  1. CLU team managers are responsible to generate and print through ALS the documents and certificates created by employees authorized under Delegation Order 5-4 found in IRM 1.2.44.4.

  2. CLU team managers or lead tax examiners are authorized to make lien release determinations and to issue certificates of release resulting from lien payoffs initiated by their employees.

5.12.6.7  (07-16-2010)
Posting, Reversing, or Updating NFTL Indicators and Recording Fees on Taxpayer Accounts

  1. Recording fees (fees paid for recording lien documents) and NFTL indicators are systemically posted to the taxpayer's account when NFTLs are filed using ALS. Transaction code (TC) 360 is used to identify the NFTL recording fee and is normally accompanied by a TC 582 NFTL indicator input in the same or next posting cycle. Occasionally, there are situations where fees posted to tax modules and/or paid to recording offices and NFTL indicators need to be updated or reversed.

    If ... Then ...
    The transaction codes do not post until after the account has been fully paid the account can be returned to a balance due status 1) ensure the NFTL sent for recording has been pulled back before it is filed or manually released if it has been filed2) reverse the posting transactions for both the NFTL indicator and fee by reversing the TC 582 with a TC 583 on the appropriate modules and inputting a TC 361 for the amount of the TC 360 filing fee
    A subsequent adjustment has totally eliminated the liability reflected on a NFTL 1) ensure the NFTL is released2) reverse the posting transactions for both the NFTL indicator and fee by reversing the TC 582 with a TC 583 on the appropriate modules and inputting a TC 361 for the amount of the TC 360 filing fee
    Accounts have been mirrored and the MFT 30 account is zero ensure the recording fee is posted to the MFT 31 account by selecting the correct MFT when creating the NFTL on ALS

5.12.6.7.1  (07-16-2010)
Payments Made to Recording Officials

  1. CLU follows up on documents paid by purchase cards or convenience checks, when recorded documents are not returned.

  2. When recording data is not received from recording offices paid by purchase cards or convenience checks, immediately contact the recording official to determine why recording data was not returned for all documents.

  3. The IRS will identify the document with the missing information.

  4. If necessary, provide a fax of the document to the recorder if they do not have a copy and obtain the recording information.

  5. If recording information is not obtained, refer to the FORT or Communications and Liaison Division (CLD) for appropriate action.

    Note:

    Review lost lien procedures for additional information.

5.12.6.7.2  (12-01-2005)
Billing Methods

  1. Three methods of payment have been established for paying fees.

    1. Direct Billing - the direct billing estimate must be annotated on the statement (e.g., billing support voucher, vendor invoice, etc.). Bulk estimates have been established, no RTS entry is needed

    2. Convenience Checks - used to provide pre-payment when required by local officials. The request for payment should be processed one day after receipt.

    3. Payment Purchase Card - annotate the statement with the bulk estimate document number. Bulk estimates have been established, no RTS entry is needed.

  2. Annotate the appropriate finance identification number for method of payment. These numbers change each fiscal year and can be obtained from the SB/SE budget office. Refer to the SBSE web site, Financial Policies and Guidelines - FY-0X (X=fiscal year).

5.12.6.7.3  (11-30-2007)
Processing Duplicate Billing Invoices

  1. Recording offices will occasionally send a duplicate billing invoice because payment has not been received.

  2. When a duplicate billing invoice is received, CLU will review their records to verify receipt and payment of the original voucher.

  3. If it is determined that the original invoice was forwarded for payment, obtain the payment date and check number. This information will be provided to the recording office.

  4. If the payment was offset (used to pay another government debt owed by the county/state), that information will be provided to the recording official along with a contact number for Financial Management Services . Further, the recording official should be informed that no other payment for that billing invoice will be made.

  5. If it is determined that the invoice was altered because their records did not match the billing support voucher or documents were not recorded that were included on the invoice, an explanation of the discrepancy should be provided. Also, provide copies of the corrected invoice, billing support voucher and unrecorded documents, if requested.

  6. If it is determined that the invoice was not forwarded for payment, follow procedures outlined in IRM 5.12.6.7.1.

5.12.6.8  (10-01-2003)
Post Payments Using Designated Payment Code 07

  1. All payments must be posted to the taxpayer's account within 48 hours of receipt.

  2. Lien Units will forward payments for posting by close of business the day of receipt.

  3. A designated payment code (DPC) is mandatory on all collection initiated posting vouchers. TC 670 is used to post money received for a lien payoff.

  4. Use DPC 07 when applying payments secured for the release of a federal tax lien.

  5. When a check is received in response to a payoff letter:

    1. Verify if the money received is the correct amount and the due date for payment as stated on the payoff letter has not passed.

    2. Verify the payment type, cashier's check, bank/postal money order, bank check, personal check.

    3. Release liens pertinent to the payment only if the tax period is full paid and the funds are certified.

5.12.6.9  (07-16-2010)
Reports

  1. A number of reports are created by ALS that directly relate to protecting the government's interest, protecting taxpayer rights, and maintaining the Service's priority. These reports, except where identified, will be resolved by the Centralized Lien Processing Unit. Supplemental procedures may be developed by the lien unit. The reports are:

    1. Satisfied Module Reject Report - this report shows modules from the weekly download, which could not be systemically processed. The report lists all modules that rejected as the result of TIN, form/period mismatch. Rejects will generate entries to the report without marking periods as satisfied. The report must be resolved weekly. Follow up actions are required on all items. This report is cumulative and modules will remain on the report until resolved. Resolved reports will be retained and filed.

    2. ACS/ICS Reject Report - This report is systemically generated each time an ACS/ICS tape is loaded to ALS daily/weekly. Liens containing invalid form types and zip codes are systemically rejected. The ACS/ICS Reject Report produces a list of taxpayers and respective POA names and addresses, liens rejected due to invalid data and liens that are duplicates. For those items that require correct name and addresses, CLU will make the appropriate correction, if necessary, and reinput the rejected item.

    3. Missing POD Report - The Missing POD report is a list of employees (usually revenue officers) who do not have matching TSIGNs in the ALS database. This report is printed weekly and is worked immediately.

    4. Lost Lien Report - The Lost Lien Report is a list of liens where no court recording data exists on ALS . This report will be worked monthly. This report may highlight problems with certain recording offices in processing liens.

    5. Potential Refile Report - The Potential Refile Lien (PRL) Report lists all liens within the refile period where the collection statute has been extended or suspended. The refile period is a 1-year period ending 30 days after the collection statute expires. When the CSED date changes on MF, the revised CSED date field is passed on to ALS. The report highlights (*) lien periods that are within the last 90 days of the refile period. Timely refiling of liens ensures that the government's priority is maintained. This report will be provided to requesting managers when requested.

      Note:

      This report is not routinely worked. Upon request, CLU will print a copy of the report for the requesting function. CLU is not responsible for any other actions regarding this report until a request for refile is received.

    6. NMF 360 Report - The NMF 360 Report provides a list of NMF modules that require manual input of TC 360 for assessment of recording fees. This report should be worked weekly.

    7. GUF - Nullified Distribution Report - provides a list of TC 582 that did not post to master file. This report should be worked within 5 days so that the lien filed indicator can be set or reversed on master file.

      Note:

      TC 583's generally do not go unpostable. When multiple TC 583's are received master file programming voids all postings after the initial TC 583 request is received.

    8. 668Y Listing - provides a list of slids requiring research, listed on the billing support voucher but are not in the ALS print queue.

    9. 668Z Listing - provides a list of slids requiring recording information research before certificates of release can be generated.

  2. CLU report resolution procedures are found in IRM 5.19.12

5.12.6.9.1  (07-16-2010)
The Potential Lost Lien Report

  1. ALS generates the Lost Lien Listing every 30 days. The listing shows the NFTLs that have been sent to recording offices but no recording information has been entered into the court screen on ALS. Any lien that is on ALS that does not have recording information is a potentially lost NFTL.

  2. Recording offices can take days, weeks or at times, months to record the lien and return it to IRS. Upon receipt of the returned recorded document, the information needs to be input to ALS to complete the recordation process.

  3. Liens taken to the recording office by Revenue Officers in the field will show as lost NFTLs if the recording information is not input to ALS. Revenue Officers are required to return the recording information to CLU so ALS can be updated.

  4. No subsequent action should be taken on a NFTL without the recording information input to ALS. This information is used by the recording office to apply any subsequent lien document to the original NFTL.

  5. The Lost Lien Report should be worked monthly.

  6. Technicians will input lien recordation data received prior to running the report.

  7. Use one of the following options to locate recording data:

    1. telephone call to the courthouse;

    2. mail-in request;

    3. Accurint;

    4. revenue officer field assistance, or,

    5. Netronline.

  8. Input recordation information, if obtained.

  9. If the lien was not received by the recording official, determine if the liability has been paid. If there is a balance due, a replacement NFTL will be prepared.

5.12.6.9.1.1  (07-16-2010)
Replacement Liens

  1. When recording information is not received and cannot be found through research by CLU, replacement NFTL may be generated and sent to recording offices. Effective December 2006, CLU will replace NFTLs and send notifications to other functions for all lost NFTLs unless there is six months or less time before the CSED.

  2. CLU issues replacement NFTLs on accounts in the following statuses:

    1. Automated Collection System - Status 22

    2. Field - Status 26

    3. Currently Not Collectible - Status 53

    4. Installment Agreement - Status 60

    5. Defaulted Installment Agreement - Status 64

  3. When replacement NFTLs are generated on ALS, do not suppress the CDP notice.

  4. For NFTLs that originated in ACS or if accounts are currently in status 22, the replacement NFTLs will be issued using an ACS assignment number.

  5. For NFTLs on accounts currently in status 60, 64, and 53, that originated in the collection field function and accounts currently in status 26 (filed by revenue officers) the replacement NFTL will be issued using the RO's (or other employee's) name who originally requested the NFTL or the current RO assignment, if in status 26.

    1. If the employee is not on ALS, the lost NFTL request will be forwarded to the revenue officer group manager where the taxpayer resides (determine group by the first six numbers of the TSIGN).

    2. Calls and requests for other actions from taxpayers on these liens will be referred to the revenue officer group manager where the taxpayer resides, or where the lien is filed based on the nature of the request.

5.12.6.9.1.2  (07-16-2010)
Identifying Liens That Require Notifications to Other Functions

  1. If it cannot be confirmed NFTLs are recorded, and taxpayers are in a status that requires specific expertise to determine if replacement NFTL filing is allowed, CLU may send notifications to other functions. Notifications will be prepared when recording information cannot be found in the following types of accounts. Phone numbers and e-mail addresses are available from the IRS Directory.

  2. Litigation - identify these accounts by:

    1. Status code 72; and

    2. the closing code that accompanied the last transaction code (TC) 520 on the tax module is 70-80, 82.

    3. Contact:
      Title: Group Manager, Advisory, Insolvency and Quality
      Mail Address: Advisory Unit where the taxpayer resides.

  3. Insolvency - identify these accounts by:

    1. Status 72 and the closing codes 60-67, 81, 83-89 with TC 520

    2. Contact.
      Title: Group Manager, Advisory, Insolvency and Quality (AIQ)
      Mail Address: Insolvency Unit where the taxpayer resides.

  4. Centralized Offer in Compromise (COIC) - identify these accounts by: Status 71 and TC 480 (no TC 780, no TC 788; and no TC 781, present on the module.)

    1. COIC - Memphis
      Contact:
      Title: Team Manager
      Mail Address: 5333 Getwell Rd, Stop 880, Memphis, TN 38118

    2. COIC - Brookhaven
      Contact:
      Title: Program Manager
      Mail Address: 1040 Waverly Avenue, Holtsville, NY 11742

  5. Monitoring Offer In Compromise (MOIC) - identify these accounts by Status 71 and TC 780.

    1. MOIC - Brookhaven
      Contact:
      Title: Department Manager, Brookhaven MOIC Unit
      Mail Address: IRS, P.O. Box 9006, Holtsville, NY 11742

    2. MOIC - Memphis
      Contact:
      Title: Department Manager, Memphis MOIC Unit
      Mail Address: IRS, 5333 Getwell Rd., Stop 813, Memphis, TN 38118

  6. Innocent Spouse - identify these accounts by:

    1. MFT 31, TC 971, AC 104.

    2. Contact


    Title: Senior Tax Analyst
    Mail Address: P. O. Box 120053, Covington, KY 41012

5.12.6.9.1.3  (07-16-2010)
Notifications About Lost Liens

  1. CLU will notify the appropriate function of actions on lost NFTLs. CLU will:

    1. Issue a Notification Regarding Lost Lien, to send lost NFTL information to the proper function for research;

    2. Identify the type of lost lien requiring research and include a description specific to the type of lost lien to assist the function in completing the requested research;

    3. Use the information in 5.12.6.9.1.12 to determine where the request should be sent;

    4. Provide information specific to the case that may assist the receiving function in conducting research and making a decision whether a replacement lien should be filed; and,

    5. Send notifications by secure E-mail.

  2. After sending the notification, CLU will remove the lien from the Lost Lien report.

5.12.6.9.1.4  (07-16-2010)
Receivers of Notifications - Procedures for Replacement Liens

  1. Notifications are sent to the function offices because the taxpayer's current collection status (litigation, bankruptcy, offer in compromise, and innocent spouse) may preclude filing a replacement NFTL. Only the function contacted via the notification - the function that specializes in actions related to the taxpayer's current collection status - can make the replacement NFTL decision.

  2. Offices that receive notifications will:

    1. determine if the notification was sent to the appropriate office based on the account status and contact information; and,

    2. assign the notification to an appropriate manager, advisor, specialist or other employee.

  3. Employees assigned notifications will:

    1. Review the tax modules and taxpayer case regarding account status, closing code information, if appropriate, other account information; and, taxpayer history, if available.

    2. Request replacement NFTL unless precluded legally or by policy. However, do not request a replacement NFTL if, based on specific case information, the new NFTL will impede collection.

  4. To file replacement NFTL, ICS users will complete Form 12636 following procedures in IRM 5.12.6.3.1.

    Note:

    Do not suppress the CDP notice.

  5. If the NFTL request is input directly into ALS, the system may query if it is a duplicate NFTL filing. If this occurs:

    1. Set answer to yes;

    2. Proceed with input; and,

    3. Do not suppress the CDP notice.

  6. If a replacement NFTL will not be filed take both of the following actions:

    1. Request input of TC 583 on the appropriate IDRS modules

    2. Request reversal of the associated TC 360

  7. As indicated, when CLU sends notifications, CLU removes the NFTL from the Lost Lien Notifications.

    1. Do not respond to CLU, they do not require your NFTL determination resolution based on their Lost Lien Notifications.

    2. If you have questions about a notification you received, contact CLU after determining the appropriate contact found on the IRS intranet http://sbse.web.irs.gov/CCP/Lien/Lien.htm .

5.12.6.9.1.5  (07-16-2010)
Actions to Avoid Issuing Releases Without Recording Information

  1. Field personnel will issue releases in accordance with procedures in IRM 5.12.3 and IRM 5.12.6.5.1.

  2. Research ALS to find the original lien's recording information. Copy the recording data from the lien being released on to the release document, Form 668Z.

  3. Send CLU a copy of the release by secure E-mail or by fax.

  4. If ALS does not have recording information for the original lien, take the following actions to find the recording information.

    1. Access the web site for recorder's office (or Secretary of State) where the lien was filed;

    2. Research using Accurint;

    3. Phone or Field call the recorder's office where the lien was filed;

    4. Contact CLU for research of the billing support vouchers to determine if the lien had been sent to the recorder and if there is any outstanding recording information to be input. Determine the proper CLU contact and secure E-mail the information.

  5. If recording information cannot be found through research, contact Advisory to determine the best course of action.

5.12.6.9.2  (07-16-2010)
ALS 668Y Listing

  1. The 668(Y) listing provides a list of slids identified on the billing support voucher but are missing from the ALS print queue.

  2. The list is printed and researched by CLU every Monday and Wednesday.

  3. The reason the slid appeared on the listing is resolved prior to printing which is scheduled for Tuesdays and Thursday.

  4. Listings are resolved within two business days.

5.12.6.9.3  (07-16-2010)
ALS 668Z Listing

  1. The 668(Z) listing provides a list of slids for liens that have been full paid but do not have data in the ALS recording data screen.

  2. The list is printed and researched by CLU every Monday and Wednesday.

  3. The reason the slid appeared on the listing is resolved prior to printing which is scheduled for Tuesday and Thursday.

  4. Listings are resolved within two business days.

5.12.6.10  (11-30-2007)
Disaster Procedures for Natural Disasters

  1. Collection Policy will simultaneously notify the CLU Operations Manager as well as Compliance Services Operations when disaster procedures are implemented prior to a nationwide notification and will provide zip codes based on information obtained from master file and the Headquarters disaster recovery analyst.

  2. The printing of the NFTL triggers the issuance of CDP notices. When the impact of the disaster may affect postal services, Policy may elect to stop the issuance of lien documents until a postal delivery determination is made. These procedures will be implemented as needed.

  3. Functional Coordinators will input the appropriate state or zip codes into ALS to ensure that liens are not created.

  4. Policy will simultaneously notify CLU and Operations when to resume NFTL generation. This decision will be based on the disaster provisions used nationwide.

5.12.6.10.1  (07-16-2010)
ALS Disaster Procedures

  1. The following procedures will be followed if there is an ALS disaster (the database is not available) lasting three days or more, and recording offices are not impacted. Lien documents will not be recorded in electronic filing courts without contingency plans, i.e., Manhattan, NY, US District Court, Boston, MA, Minnesota, LA County, CA, and the Connecticut Secretary of State.

  2. Lien documents will be prepared for jeopardy/termination or hardship situations.

  3. Revenue officers and advisors will:

    1. use ICS template forms to prepare lien documents.

    2. create a SLID using the area/group/territory/employee TSIGN, then sequential numbering, e.g., 211003231222-01,

    3. record documents locally, when appropriate.

    4. attach prepared documents to Form 3210 for lien documents requiring recordation in other areas and secure e-mail a request to record the document after determining the appropriate group. The receiving group will record the lien document and return recording information to the requesting employee within 7 calendar days.

    5. post transaction codes TC 582 to set lien filed indicator and TC 360 with the appropriate recording fee.

    6. document case histories, including the date forwarded to CLU and the serial number from (3)(b).

    7. secure e-mail CLU copies of recorded documents.

  4. Employees without ICS access will use the Intranet fillable forms to prepare lien documents. Requests will be secure emailed to CLU. The procedures outlined in (3)(a) through (3)(f) will be followed.

  5. When a NFTL is issued, the appropriate collection due process notice with enclosures will be prepared and mailed by requesting employees. Certified or registered mail will be used when appropriate. Issue one of the following notices.

    1. L3172, Notice of Federal Tax Lien Filing and Your Rights to a Hearing Under IRC 6320,

    2. L3171, Notice of Federal Tax Lien Filing,

    3. L3177, Letter Notifying of Federal Tax Lien Filing-Nominee or Alter-Ego,

    4. L3527, Notice of Federal Tax Lien Filing - Child Support Obligation,

    5. L3886, Notice to Taxpayer of Nominee/Alter-Ego of Federal Tax Lien Filing.

  6. Employees will document case histories with lien filing or release request information. Include sufficient information to identify the request.

  7. When ALS production resumes, CLU will input these documents to the database using SCreate from documents provided by the requesting employee.

5.12.6.11  (07-16-2010)
Field Office Resource Team (FORT)

  1. The Field Office Resource Team (FORT) acts as a technical resource and liaison for the Lien Processing Units. A staff revenue officer/advisor responds to employee requests or determines if assistance from some other function is required.

  2. Generally the FORT:

    1. Obtains information on lien issues from field employees, as necessary

    2. Communicates with Headquarters Analysts

    3. Resolves issues with recording offices, if possible

    4. Initiates Contact with area counsel and governmental liaison offices as well as maintaining associated nationwide contact lists

    5. Responds to questions regarding new procedures

    6. Assists in implementing new or revised procedures

    7. Explains and interprets IRM procedures, when necessary

    8. Provides technical guidance to internal and external customers

    9. Responds to questions from field employees related to centralized lien processing

    10. Encourages Lien Processing employees to contact field employees to resolve non-technical issues

5.12.6.12  (07-16-2010)
Contacting Recording Officials

  1. Upon receipt of a complaint, CLU may contact recording officials, to ascertain the issue to be resolved, without contacting Collection Policy Technical.

  2. Decide on a list of actions to be taken to resolve the issue.

  3. Contact area counsel and/or the local governmental liaison staff to determine if policies or practices have been established.

  4. Contact the recording official and outline our procedures and any code or regulation requirements.

  5. Within 10 calendar days, contact the Headquarters Policy analyst(s) and provide information regarding attempted resolution if the issue is not resolved.

  6. Collection Policy with SBSE Counsel, if necessary, will determine further appropriate corrective actions.

5.12.6.12.1  (03-15-2005)
Resolving Issues with Recording Officials

  1. Contact the recording official.

  2. Explain the Service's position and attempt to resolve the issue.

  3. Document any conversations and also retain any correspondence received from the official.

  4. Initiate corrective actions if you determine that established policies or procedures have not been followed.

  5. If it is determined that procedural changes are required, initiate a systems change request and submit to Headquarters for approval.

  6. Request interim guidance, if necessary.

5.12.6.13  (07-16-2010)
Communicating With the Centralized Lien Unit

  1. Field employees may contact the CLU team for their Area for problems with a specific lien. If the problem is not resolved or if it is a general problem impacting many liens, the employee may contact the FORT. Contact with CLU or the FORT may be by phone, fax, or secure e-mail.

  2. CLU will identify concerns and take any necessary corrective actions. The Lien Unit can resolve issues regarding lien filings including:

    1. missing TIN,

    2. incorrect name control,

    3. incorrect tax period,

    4. incorrect type of tax, etc.

  3. CLU will notify the field employee of the resolution.

  4. Occasionally, the Lien Processing employee will need to refer an issue to the FORT. Referrals from Lien Processing employees to the FORT will be forwarded through the Lien Processing manager.

  5. The FORT will identify issues/concerns that should be resolved by the Lien Unit and return them through the FORT manager with information to resolve the concerns.

  6. The FORT will assist CLU in determining what actions should be taken when:

    1. a TE is completing a payoff request and determines that there is a pending property transaction and NFTLs have not been filed on all periods.

    2. a taxpayer requests a release and can show that the liability is satisfied but the controlling function has no record of payment,

    3. disclosure of taxpayer information may be inappropriate.

  7. The FORT will determine if other functions are involved and, if so, initiate contact.

  8. Referrals related to possible additional collection activity should be resolved in a timely manner. para

  9. For assistance with the ALS database on changes such as POD addresses, group numbers, and county/zip code matches, the field employee should contact the local ICS IQ Analyst who will coordinate the changes with the Lien Policy Analysts or ALS Functional Coordinator. For other contact with the ALS Coordinator, see IRM 5.12.6.2.

Exhibit 5.12.6-1 
ALS Permissions Chart

Automated Lien System (ALS) access options have been established for the following employees, including affiliated tax examiners, clerks and group secretaries. Permissions must be approved by managers and may be altered to meet specific employee needs.

Permission RO TAS and Appeals MOIC (Monitoring Offers in Compromise) COIC (Centralized Offer in Compromise) Collection Advisory and Field Insolvency CIO (Centralized Insolvency Office)
Create a Lien       x x x
Research Lien Information x x x x x x
Request Lien Release     x x x x
Withdrawal         x  
Revocations         x  
Partial Release         x x
Refile a Lien x       x x
Input Court Data x       x  
Update a Lien (History)       x x x
Input POA Information (NOTADD) x     x x  
Print Facsimiles       x x x
Amend x       x  
Approve     x x
managers only 		x  
Edit a Lien       x    
Bypass         *x
managers approval required 		*x
managers only

Exhibit 5.12.6-2 
Request for Filing and Refiling Notice of Federal Tax Lien

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Exhibit 5.12.6-3 
Notice of Lien (MCAR)

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