Letter 2423 is the IRS's response to an administrative appeal you filed about a Notice of Federal Tax Lien. IRM 5.12.3 uses it in two situations: when your request does not meet the criteria for an administrative appeal or is being referred to another function, and when the appeal is denied.
What an Administrative Lien Appeal Covers
Under IRC Section 6326, you can appeal the filing of a Notice of Federal Tax Lien on the ground that it was filed in error. Examples include a lien filed after the tax was paid, filed after the collection statute expired, filed while you were in bankruptcy, or filed against the wrong person. If the IRS agrees, it releases the lien and can issue a letter of apology that you can show to credit agencies and lenders.
If Your Appeal Was Denied
An administrative appeal is narrow. A lien that was properly filed against a real balance will not be released through this process, no matter how much it hurts your credit. That does not mean you are out of options. Lien withdrawal under IRC Section 6323(j), discharge of specific property under IRC Section 6325(b), subordination under IRC Section 6325(d), and release once the balance is paid or becomes unenforceable all remain available. A Collection Due Process hearing on Letter 3172 is another route if you are still within its deadline.
If you received Letter 2423, call us at (813) 229-7100. The right lien remedy depends on what you need the property for.