A tax lien is a type of claim against property that secures the payment of a tax debt. A Federal Tax Lien is a non-consensual lien that gives the IRS an interest in the taxpayer’s property (this interest will allow the IRS to seize and sell the taxpayer’s property in order to satisfy an assessment). Under §6321, the tax lien is imposed in favor of the United States Treasury when an assessment has been made by the IRS, a notice and demand for payment has been made, and the taxpayer has neglected or refused to pay the assessment. Under §6322, the IRS tax lien arises at the time the assessment was made.
The lien attaches to all property and rights to property belonging to the taxpayer at the time the lien arises as well as any property acquired after the lien arises. The IRS files a Notice of Federal Tax Lien to put the taxpayer’s other creditors on notice that the IRS has a claim against all of the taxpayer’s property. The IRS lien continues until liability for the assessment is satisfied by payment or abatement, or the assessment becomes unenforceable by reason of lapse of time.
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