26 U.S.C. § 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.
Notes of Decisions
Cited in 1,578
cases (135 in the last 5 years), 1956–2026 · leading case: United States v. Craft
United States v. Craft (2002)
“26 U. S. C. § 6321 . Relying on the state law fiction that a tenant by the entirety has no separate interest in entireties property, the United States Court of Appeals for the Sixth Circuit held that such property is exempt from the tax lien.”
Rushmore State Bank v. Kurylas, Inc. (1988)
“Is the United States entitled to priority of escrow funds by virtue of 26 U.S.C. § 6321 ? FACTS Prior to 1983, Kurylas owned a motel, restaurant and lounge complex in Rapid City, South Dakota.”
United States v. Rodgers (1983)
“" As a general matter, [1] the "lien of the United States" referred to in § 7403(a) is that created by 26 U. S. C. § 6321 , which provides: "If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount (including any *682 interest, additional…”
Ali v. Federal Bureau of Prisons (2008)
“Under 26 U.S.C. § 6321 , a delinquent taxpayer's property is subject to forfeiture, see Glass City Bank v.”
United States Ex Rel. Internal Revenue Service v. McDermott (1993)
“Upon that assessment, the law created a lien in favor of the United States on all real and personal property belonging to the McDermotts, 26 U. S. C. §§ 6321 and 6322, including after-acquired property, Glass City Bank v.”
Drye v. United States (2000)
“This case presents the question whether Drye’s interest as heir to his mother’s estate constituted "property” or a “righ[t] to property” to which the federal tax liens attached under 26 U. S. C. § 6321 , despite Drye’s exercise of the prerogative state law accorded him to…”
United States v. Estate of Romani (1998)
“[1] The question presented is whether that statute requires that a federal tax claim be given preference over a judgment creditor's perfected lien on real property even though such a preference is not authorized by the Federal Tax Lien Act of 1966, 26 U. S. C. § 6321 et seq. I…”
United States v. Hopkins (2013)
“The United States cites to 26 U.S.C. § 6321 for the proposition that Hopkins’ federal tax liens arose automatically against them on the day the IRS made the assessment, and that the liens are effective against all of the Hopkins’ property rights whether existing or acquired…”
United States v. National Bank of Commerce (1985)
“II A Section 6321 of the Code, 26 U. S. C. § 6321 , provides: "If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount .”
United States v. Williams (1995)
“See 26 U. S. C. § 6321 ("If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount .”
Musolino v. Sinnreich (In Re Sinnreich) (2004)
“*1298 The Supreme Court then examined the IRS’s powers granted by 26 U.S.C. § 6321 to determine if the IRS may pull any of the individual right “sticks” that a defaulted taxpayer may have out of the idiomatic bundle in order to encumber property owed with a spouse by the…”
Congress Talcott Corporation v. Gabriel Gruber Lawrence Herman United States of America (1993)
“26 U.S.C. § 6321 . To enforce its lien, the government may initiate an administrative levy under section 6331(a).”
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