26 U.S.C. § 6322
Period of lien
Unless another date is specifically fixed by law, the lien imposed by section 6321 shall arise at the time the assessment is made and shall continue until the liability for the amount so assessed (or a judgment against the taxpayer arising out of such liability) is satisfied or becomes unenforceable by reason of lapse of time.
Notes of Decisions
Cited in 484
cases (31 in the last 5 years), 1956–2026 · leading case: United States v. Rodgers
United States v. Rodgers (1983)
“See also 26 U. S. C. § 6322 (period of lien); 26 U.”
United States v. Williams (1995)
“A federal tax lien securing the taxes and interest owed by Rabin arose "at the time the assessment [was] made," 26 U. S. C. § 6322 , and reached "all property and rights to property, whether real or personal, belonging to" Rabin at that time.”
McGimpsey v. D&L Ventures, Inc. (2019)
“26 U.S.C. § 6322 ; I.C. § 63-3045A(1). Idaho law provides: "no tax commission activities to enforce collection of tax may be conducted, nor may a proceeding to collect a tax be instituted, until taxes are assessed in accordance with the provisions of this section.”
Khan v. BDO Seidman, LLP (2011)
“26 U.S.C. §6322 (2006). Thus, “ ‘in the federal scheme[,] assessment involves the taking of an interest in the taxpayer’s property after affording the taxpayer notice of an alleged deficiency and an opportunity to challenge the deficiency.”
Peggy Ann Schaefer Spotts v. United States (2005)
“1 Section 6322 provides that “the lien imposed by section 6321 shall arise at the time the assessment is made and shall continue until the liability for the amount so assessed (or a judgment against the taxpayer arising out of such liability) is satisfied or becomes…”
Abex Corporation v. Ski's Enterprises, Inc. And United States of America v. Walton Shim and Sandra Shim (1984)
“Abex contends that the EAJA abrogates the government’s tax lien priority to allow an award of fees to the interpleader plaintiff.”
United States v. Hopkins (2013)
“See 26 U.S.C. § 6322 (“Unless another date is specifically fixed by law, the lien imposed by section 6321 shall arise at the time the assessment is made and shall continue until the liability for the amount so assessed .”
Morrow v. United States (2010)
“§ 6751 , by failing to verify in writing that a supervisor had approved, in writing, any initial tax penalty determination (Count 24); • 26 U.S.C. § 6322 , by asserting liens for which no assessment was made in accordance with 26 U.”
Texas Oil & Gas Corporation v. The United States of America, the Pecos County State Bank (1972)
“26 U.S. C.A. § 6322. 10 And a federal tax lien, duly filed, becomes enforceable immediately against all after-acquired property.”
Drye v. United States (2000)
“” 26 U. S. C. § 6322 . 3 See Pennell, Recent Wealth Transfer Tax Developments, in Sophisticated Estate Planning Techniques 69, 117-118 (ALI-ABA Continuing Legal Ed.”
United States v. Central Bank of Denver (1988)
“26 U.S. C. § 6322. 6 Such a lien takes priority over liens attaching subsequent to the assessment of the delinquent tax.”
J.D. Court, Inc., a Corporation v. United States of America, Acting Through the Department of Treasury, Internal Revenue (1983)
“7 Section 6323(a) 8 of the Act creates an exception to § 6322’s rule that a federal tax lien generally attaches at the time the delinquent tax is assessed; under § 6323(a), when the “holder of a security interest” also claims an interest in property subject to a federal tax…”
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