Printable Form 2026

IRS Publication 1153 – IRS Forms, Instructions, Pubs 2026

IRS Publication 1153 – IRS Forms, Instructions, Pubs 2026 – If you’re dealing with a federal estate tax lien on inherited property and need to refinance, borrow against it, or place a new mortgage, IRS Publication 1153 provides the official guidance on requesting a certificate of subordination under Internal Revenue Code (IRC) Section 6325(d)(3). This short but essential IRS publication explains exactly how to prepare and submit an application when no standard form exists.

Published in June 2018 (Rev. 6-2018, Catalog Number 62173C) and still the current version as of 2026, Publication 1153 remains the authoritative source on IRS.gov for this specific process. You can download the full PDF directly here: https://www.irs.gov/pub/irs-pdf/p1153.pdf.

What Is a Federal Estate Tax Lien?

Under IRC Section 6324, a special lien automatically arises upon a decedent’s death for any unpaid federal estate tax. This lien attaches to the gross estate and can remain in effect for up to 10 years. The IRS may also file a Notice of Federal Estate Tax Lien (Form 668-H or similar) in public records, which clouds title and complicates sales, refinances, or new loans.

A certificate of subordination allows the IRS to agree that its estate tax lien will take a lower priority behind a new lender’s interest (such as a mortgage or home equity loan). This is authorized specifically under IRC Section 6325(d)(3) for estate tax liens, distinct from general federal tax lien subordinations handled under Publication 784 and Form 14134.

When Do You Need Publication 1153?

Use Publication 1153 when:

  • You (or a qualified heir, executor, or representative) want to place new financing on property subject to a federal estate tax lien.
  • The new loan or encumbrance will not fully pay off the estate tax but the IRS determines subordination serves the government’s interest (typically by preserving or enhancing the value of remaining secured assets).
  • You need clear title or senior lien position for a lender.

Note: This publication applies only to federal estate tax liens. For income tax or other general federal tax liens, refer instead to Publication 784 (“How to Prepare an Application for a Certificate of Subordination of Federal Tax Lien”) and Form 14134.

Step-by-Step Guide: How to Apply per IRS Publication 1153?

Publication 1153 emphasizes that no official application form exists. A clear, typewritten (or neatly prepared) letter or statement counts as a formal application if it includes all required details and a perjury declaration.

1. Prepare Your Application

Include the following information (numbered exactly as in Publication 1153 for IRS reviewers):

  1. Date of application and your full name and address as the applicant.
  2. Name and address of the decedent at time of death, plus a detailed property description (for real estate, use the exact legal description from the deed/title plus full street address, city, state, ZIP).
  3. Copies of every Notice of Federal Estate Tax Lien filed, or equivalent details: IRS area, taxpayer name/address, serial number, TIN, filing date and place (or attach a preliminary title report).
  4. Full description of the proposed new encumbrance (mortgage, assignment, etc.), including amount (present and/or proposed), nature, and expected closing date.
  5. List of all prior/senior encumbrances on the property (or attach instruments), with holder name/address, description, date, recording info, original principal, interest rate, current balance (separating costs and accrued interest), and any family relationship to holders.
  6. Fair market value estimate of the subject property (with basis for the valuation) + separate estimate for any remaining property still subject to the estate tax lien.
  7. Names, addresses, and Social Security numbers of the decedent’s estate and any qualified heirs for the property.
  8. If you (or your representative) are not the estate’s designated IRS contact, attach written authorization.
  9. Purpose of the loan.
  10. Loan amount, repayment terms, lender’s exact name/address, and contact person’s name and phone number.
  11. Your daytime telephone number.
  12. Name, address, and phone of your attorney or legal representative (if any).

Required closing statement (verbatim from Pub 1153):
“Under penalties of perjury, I declare that I have examined this application (including any accompanying schedules, exhibits, affidavits, and statements) and to the best of my knowledge and belief, it is true, correct, and complete.”

Sign and date it with your title (e.g., Executor, Heir, Authorized Representative).

2. Gather Supporting Documents

  • Copies of liens or title report
  • Proposed loan documents (if available)
  • Appraisal or valuation support (professional appraisal strongly recommended)
  • Authorization letter (if needed)
  • Any other evidence showing subordination benefits the government’s collection interest

3. Submit the Application

Mail or e-fax the complete package to:
Internal Revenue Service
Advisory Estate Tax Lien Group
55 South Market St., Mail Stop 5350
San Jose, CA 95113-2324
Attn: Group Manager

E-fax: 877-477-9243

Current contact (per latest IRS Publication 4235, Rev. 10-2024): Phone (669) 229-1504 for questions (not for initial submission).

Submit at least 45–60 days before your planned closing to allow processing time. The IRS may request additional information.

Tips for a Stronger Application

  • Be thorough and organized — IRS Advisory reviews these manually.
  • Include professional appraisals and clear title reports to demonstrate adequate security for the remaining lien.
  • Explain in a cover letter how subordination serves the best interest of the United States (e.g., new financing maintains or increases property value).
  • Work with an estate attorney or tax professional experienced in IRS liens.
  • Track all correspondence and keep copies.
  • Publication 1153 PDF (this article’s source)
  • Publication 784 – General tax lien subordination
  • Form 14134 – Application for Certificate of Subordination of Federal Tax Lien (general use)
  • Publication 4235 – Collection Advisory Group Addresses (latest office contacts)
  • IRM 5.12.10 – Internal Revenue Manual section on lien-related certificates
  • IRS page: Understanding a Federal Tax Lien

Important Disclaimer

This article summarizes IRS Publication 1153 and related official guidance for informational purposes only. Tax laws and procedures can change, and individual circumstances vary. Publication 1153 does not guarantee approval—subordination is issued only when in the government’s best interest. Always consult a qualified tax attorney, CPA, or enrolled agent familiar with estate tax liens before submitting any application. This is not legal or tax advice.

Final Thoughts

Navigating a federal estate tax lien can delay important financial transactions, but IRS Publication 1153 gives you a clear roadmap to request subordination under Section 6325(d)(3). By following the publication’s detailed requirements and submitting a complete application to the Advisory Estate Tax Lien Group in San Jose, you maximize your chances of obtaining the certificate you need.

For the most current instructions, always download the latest PDF from IRS.gov and cross-reference Publication 4235 for contact details. If your situation involves selling (rather than borrowing against) estate property, you may instead need a certificate of discharge—see Form 4422 or Publication 783.

Keywords: IRS Publication 1153, certificate of subordination estate tax lien, IRC 6325(d)(3), federal estate tax lien subordination, how to apply for IRS estate tax lien subordination, Advisory Estate Tax Lien Group San Jose.

Last updated based on IRS sources as of February 2026. Always verify directly on IRS.gov.