Internal
Revenue Code 6321
Internal Revenue Code: §6321.
LIEN FOR TAXES.
If any person liable to
pay any tax neglects or refuses
to pay the same after demand, the amount (including any interest,
additional amount, addition to tax, or assessable penalty, together with
any costs that may accrue in addition thereto) shall be a lien in favor
of the United States upon all
property and rights to property, whether real or personal, belonging to
such person.
§301.6321-1 of
Treasury Regulations provides:
Lien for taxes. --If
any person liable to pay any tax neglects or refuses to pay the same
after demand, the amount (including any interest, additional amount,
addition to tax, or assessable penalty, together with any costs that may
accrue in addition thereto) shall be a lien in favor of the United
States upon all property and rights to property, whether real or
personal, tangible or intangible, belonging to such person. For purposes
of section 6321 and this section, the term "any tax" shall
include a State individual income tax which is a "qualified
tax", as defined in paragraph (b) of §301.6361-4. The lien
attaches to all property and rights to property belonging to such person
at any time during the period of the lien, including any property or
rights to property acquired by such person after the lien arises. Solely
for purposes of sections 6321 and 6331, any interest in restricted land
held in trust by the United States for an individual noncompetent Indian
(and not for a tribe) shall not be deemed to be property, or a right to
property, belonging to such Indian. For the method of allocating amounts
collected pursuant to a lien between the Federal Government and a State
or States imposing a qualified tax with respect to which the lien
attached, see paragraph (f) of §301.6361-1. For the special lien for
estate and gift taxes, see section 6324 and §301.6324-1.
.01 Historical Comment: Proposed 12/11/54. Adopted
12/31/54 by T.D.
6119. Amended 8/11/71 by T.D.
7139 and 12/19/78 by T.D.
7577.
