26 U.S.C. § 6324

Special liens for estate and gift taxes

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(a) Liens for estate taxExcept as otherwise provided in subsection (c)—(1) Upon gross estate

Unless the estate tax imposed by chapter 11 is sooner paid in full, or becomes unenforceable by reason of lapse of time, it shall be a lien upon the gross estate of the decedent for 10 years from the date of death, except that such part of the gross estate as is used for the payment of charges against the estate and expenses of its administration, allowed by any court having jurisdiction thereof, shall be divested of such lien.

(2) Liability of transferees and others

If the estate tax imposed by chapter 11 is not paid when due, then the spouse, transferee, trustee (except the trustee of an employees’ trust which meets the requirements of section 401(a)), surviving tenant, person in possession of the property by reason of the exercise, nonexercise, or release of a power of appointment, or beneficiary, who receives, or has on the date of the decedent’s death, property included in the gross estate under sections 2034 to 2042, inclusive, to the extent of the value, at the time of the decedent’s death, of such property, shall be personally liable for such tax. Any part of such property transferred by (or transferred by a transferee of) such spouse, transferee, trustee, surviving tenant, person in possession, or beneficiary, to a purchaser or holder of a security interest shall be divested of the lien provided in paragraph (1) and a like lien shall then attach to all the property of such spouse, transferee, trustee, surviving tenant, person in possession, or beneficiary, or transferee of any such person, except any part transferred to a purchaser or a holder of a security interest.

(3) Continuance after discharge of fiduciary

The provisions of section 2204 (relating to discharge of fiduciary from personal liability) shall not operate as a release of any part of the gross estate from the lien for any deficiency that may thereafter be determined to be due, unless such part of the gross estate (or any interest therein) has been transferred to a purchaser or a holder of a security interest, in which case such part (or such interest) shall not be subject to a lien or to any claim or demand for any such deficiency, but the lien shall attach to the consideration received from such purchaser or holder of a security interest, by the heirs, legatees, devisees, or distributees.

(b) Lien for gift tax

Except as otherwise provided in subsection (c), unless the gift tax imposed by chapter 12 is sooner paid in full or becomes unenforceable by reason of lapse of time, such tax shall be a lien upon all gifts made during the period for which the return was filed, for 10 years from the date the gifts are made. If the tax is not paid when due, the donee of any gift shall be personally liable for such tax to the extent of the value of such gift. Any part of the property comprised in the gift transferred by the donee (or by a transferee of the donee) to a purchaser or holder of a security interest shall be divested of the lien imposed by this subsection and such lien, to the extent of the value of such gift, shall attach to all the property (including after-acquired property) of the donee (or the transferee) except any part transferred to a purchaser or holder of a security interest.

(c) Exceptions(1) The lien imposed by subsection (a) or (b) shall not be valid as against a mechanic’s lienor and, subject to the conditions provided by section 6323(b) (relating to protection for certain interests even though notice filed), shall not be valid with respect to any lien or interest described in section 6323(b).(2) If a lien imposed by subsection (a) or (b) is not valid as against a lien or security interest, the priority of such lien or security interest shall extend to any item described in section 6323(e) (relating to priority of interest and expenses) to the extent that, under local law, such item has the same priority as the lien or security interest to which it relates.(Aug. 16, 1954, ch. 736, 68A Stat. 780; Pub. L. 88–272, title II, § 236(b), (c)(2), Feb. 26, 1964, 78 Stat. 127, 128; Pub. L. 89–719, title I, § 102, Nov. 2, 1966, 80 Stat. 1132; Pub. L. 91–614, title I, §§ 101(d)(2), 102(d)(7), Dec. 31, 1970, 84 Stat. 1837, 1842.)Editorial NotesAmendments

1970—Subsec. (a)(3). Pub. L. 91–614, § 101(d)(2), substituted “fiduciary” for “executor” in heading and text.

Subsec. (b). Pub. L. 91–614, § 102(d)(7), substituted “period for which the return was filed” for “calendar year”.

1966—Subsec. (a)(1). Pub. L. 89–719 inserted “, or becomes unenforceable by reason of lapse of time,” after “sooner paid in full” and substituted “10 years from the date of death” for “10 years upon the gross estate of the decedent”.

Subsec. (a)(2). Pub. L. 89–719 substituted “person in possession, or beneficiary, to a purchaser or holder of a security interest” for “person in possession of property by reason of the exercise, nonexercise, or release of a power of appointment, or beneficiary, to a bona fide purchaser, mortgagee, or pledgee, for an adequate and full consideration in money and money’s worth” and “except any part transferred to a purchaser or a holder of a security interest” for “except any part transferred to a bona fide purchaser, mortgagee, or pledgee for an adequate and full consideration in money or money’s worth”.

Subsec. (a)(3). Pub. L. 89–719 substituted “purchaser or a holder of a security interest” for “bona fide purchaser, mortgagee, or pledgee for an adequate and full consideration in money or money’s worth” and “purchaser or holder of a security interest” for “purchaser, mortgagee, or pledgee”.

Subsec. (b). Pub. L. 89–719 substituted reference to exception provided in subsec. (c) for reference to exceptions provided in subsecs. (c) and (d), inserted reference to tax becoming unenforceable by reason of lapse of time, and substituted “purchaser or holder of a security interest” for “bona-fide purchaser, mortgagee, or pledgee, for an adequate and full consideration in money or money’s worth”.

Subsec. (c). Pub. L. 89–719 redesignated as par. (1) provisions formerly constituting subsec. (c), substituted “valid as against a mechanic’s lienor and, subject to the conditions provided by section 6323(b) (relating to protection for certain interests even though noticed filed), shall not be valid with respect to any lien or interest described in section 6323(b)” for “valid with respect to a security, as defined in section 6323(c)(2), as against any mortgagee, pledgee, or purchaser of any such security, for an adequate and full consideration in money or money’s worth, if at the time of such mortgage, pledge, or purchase such mortgagee, pledgee, or purchaser is without notice or knowledge of the existence of such lien”, and added par. (2).

Subsec. (d). Pub. L. 89–719 struck out subsec. (d) dealing with exceptions in the case of motor vehicles. See subsec. (c) above and reference therein to section 6323(b).

1964—Subsecs. (a), (b). Pub. L. 88–272, § 236(c)(2), inserted “and subsection (d) (relating to purchases of motor vehicles)”.

Subsec. (d). Pub. L. 88–272, § 236(b), added subsec. (d).

Statutory Notes and Related SubsidiariesEffective Date of 1970 Amendment

Amendment by section 101(d)(2) of Pub. L. 91–614 applicable with respect to decedents dying after Dec. 31, 1970, see section 101(j) of Pub. L. 91–614, set out as a note under section 2032 of this title.

Amendment by section 102(d)(7) of Pub. L. 91–614 applicable with respect to gifts made after Dec. 31, 1970, see section 102(e) of Pub. L. 91–614, set out as a note under section 2501 of this title.

Effective Date of 1966 Amendment

Amendment by Pub. L. 89–719 applicable after Nov. 2, 1966, regardless of when title or lien of United States arose or when lien or interest of another person was acquired, with certain exceptions, see section 114(a)–(c) of Pub. L. 89–719, set out as a note under section 6323 of this title.

Effective Date of 1964 Amendment

Amendment by Pub. L. 88–272 applicable to purchases made after Feb. 26, 1964, see section 236(d) of Pub. L. 88–272, set out as a note under section 6323 of this title.

Notes of Decisions

Cited in 91 cases (6 in the last 5 years), 1961–2026 · leading case: United States v. James D. Paulson, 68 F.4th 528 (9th Cir. 2023).

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United States v. James D. Paulson, 68 F.4th 528 (9th Cir. 2023). · cites it 21× “The United States sued several heirs of Allen Paulson, alleging that they were trustees of Paulson’s trust or received estate property as transferees or beneficiaries, and were thus personally liable for estate taxes under 26 U.S.C. § 6324 (a)(2). The United States also alleged…”

United States v. Finley Hilliard, 798 F.3d 296 (5th Cir. 2015). · cites it 14× “OWEN, Circuit Judge, writing for the court: * One of the principal issues in this appeal is whether a donee’s liability for a donor’s unpaid gift tax and interest on that tax is limited under 26 U.S.C. § 6324 (b) to the value of the gift of the donee.”

United States v. Botefuhr, 309 F.3d 1263 (10th Cir. 2002). · cites it 8× “See 26 U.S.C. § 6324 (b). On appeal, the Appellants raise three issues: first, whether the district court had personal jurisdiction over Botefuhr and Davenport; second, whether the statute of limitations for collecting taxes under § 6324(b) has expired; 1 and third, whether,…”

Gabriel J. Baptiste, Jr., Transferee v. Comm'r of Internal Revenue, 29 F.3d 433 (8th Cir. 1994). · cites it 9× “’s Estate for purposes of determining Gabriel’s transferee liability pursuant to 26 U.S.C. § 6324 (a), and (2) he was liable for interest on the amount of his personal liability for unpaid estate tax, beyond the value of the property transferred, accrued since the due date of…”

USA/Internal Revenue Serv. v. Valley Nat'l Bank (In Re Decker), 199 B.R. 684 (9th Cir. BAP 1996). · cites it 8× “" 26 U.S.C. § 6324 (a)(1). This lien does not need to be recorded to be valid, even against a subsequent purchaser for value with no actual knowledge of the lien.”

United States v. Johnson, 920 F.3d 639 (10th Cir. 2019). · cites it 5× “See 26 U.S.C. § 6324 (a)(2). Appellees' motion to dismiss the § 6324(a)(2) claim was granted in part and denied in part.”

United States v. Finley Hilliard, 771 F.3d 854 (5th Cir. 2014). · cites it 10× “OWEN, Circuit Judge, concurring in part, dissenting in part: I agree with the Third Circuit’s resolution of the question of whether a donee’s liability for the donor’s unpaid gift tax and interest on that tax is limited under 26 U.S.C. § 6324 (b) to the value of the gift to the…”

United States v. Warren B. Davis, Tr. of the Warren B. Davis Revocable Living Trust, & Westwood Indus. Park, Ltd., 52 F.3d 781 (8th Cir. 1995). · cites it 5× “This appeal requires us to visit a narrow question: whether the 10-year period set forth in the estate tax lien statute, 26 U.S.C. § 6324 (a)(1), is durational or limitational.”

Chevron, U.S.A., Inc. v. United States, 705 F.2d 1487 (9th Cir. 1983). · cites it 4× “§ 6321 1 or its special estate tax liens deriving from 26 U.S.C. § 6324 (a)(1). 2 We reverse. FACTS William Bazinett is the sole heir and executor of the estates of his parents, Catherine and Joseph, who died on September 25, 1970, and May 4, 1971, respectively.”

United States v. Paulson, 331 F. Supp. 3d 1066 (S.D. Cal. 2018). · cites it 8× “) Specifically, Co-Trustees assert that early in this case, the Court granted their motion to dismiss Plaintiff's claims against them under 26 U.S.C. § 6324 (a)(2). ( Id. ) Thus, according to Co-Trustees, the summary judgment motions at issue seek reconsideration of that ruling…”

United States v. Patrick D. Rotherham, 836 F.2d 359 (7th Cir. 1988). · cites it 5× “Under 26 U.S.C. § 6324 (a)(2) (1982), 1 the tax was owed by Edwards and a lien automatically attached to the land.”

Diedrich v. Comm'r, 457 U.S. 191 (1982). · cites it 2× “26 U. S. C. § 6324 (b). The donee's liability, however, is limited to the value of the gift.”

Amanda York Beaty & Nancie York Gunter v. United States, 937 F.2d 288 (6th Cir. 1991). · cites it 3× “II 26 U.S.C. § 6324 (a)(1) provides that, if the estate tax is not paid (or otherwise discharged by the passage of time) “it shall be a lien upon the gross estate of the decedent for 10 years from the date of death_” The special estate tax lien differs from the § 6321 general…”

United States v. Johnson, 224 F. Supp. 3d 1220 (D. Utah 2016). · cites it 6× “PROCEDURAL BACKGROUND The government filed this action oh January 21, 2011 in an effort to collect the estate’s outstanding tax liability, asserting a eause of action against all defendants for trustee, transferee, and beneficiary liability under 26 U.S.C. § 6324 (a)(2), and…”

United States v. Birnie Davenport, Gordon E. Davenport, 484 F.3d 321 (5th Cir. 2007). “The do-nee may also be held personally liable for the full amount of any unpaid gift tax pursuant to 26 U.S.C. § 6324 (b). 7 Although the donee’s liability is limited to the value of the gift he received from the donor, he may be forced to pay more than the gift tax attributable…”

Janet Metz v. United States, 933 F.2d 802 (10th Cir. 1991). · cites it 2× “The estate tax lien under 26 U.S.C. § 6324 (a)(1) attaches on the date of death to the value of the gross estate.”

United States v. Saleh, 514 F. Supp. 8 (D.N.J. 1980). · cites it 3× “FACTS This is an action to foreclose so-called “special” estate tax liens imposed under 26 U.S.C. § 6324 (a)(l). Decedent Menashi J.”

Est. of O'Neal v. United States, 81 F. Supp. 2d 1205 (N.D. Ala. 2000). · cites it 7× “On April 28, 1998, the Tax Court ruled against the donees, holding that: (1) the grandchildren donees can be held personally liable for the transferee gift (and generation-skipping transfer) tax under 26 U.S.C. § 6324 (b), without any requirement that the IRS must first assert…”

United States v. Michael Norwood, 49 F.4th 189 (3rd Cir. 2022). “1995), the Eighth Circuit neatly summed up the difference in the context of another tax lien statute, 26 U.S.C. § 6324 (a)(1): “If the period is durational, the government has ten years to enforce the lien before it expires.”

New England Acceptance Corp. v. United States, 35 F. Supp. 2d 53 (D.N.H. 1997). · cites it 6× “Term of Special Gift Tax Lien 26 U.S.C. § 6324 (b) provides, in relevant part, that unless the gift tax imposed .”

Batchelor-Robjohns v. United States, 788 F.3d 1280 (11th Cir. 2015). · cites it 3× “The government then filed suit in federal district court against both the estate and the recipients of the stock gifts as transferees pursuant to 26 U.S.C. § 6324 (b). 17 The Fifth Circuit found that the two suits involved the same operative facts and underlying transactions, as…”

Wilkes v. United States, 50 F. Supp. 2d 1281 (M.D. Fla. 1999). · cites it 4× “See 26 U.S.C. § 6324 (a)(1). Second, if the estate tax is not paid in full when due but property of the decedent is transferred to another (including transferees, beneficiaries, and those in possession of gross estate property on the date of the decedent’s death), then those…”

United States v. Est. of Davenport, 159 F. Supp. 2d 1330 (N.D. Okla. 2001). · cites it 2× “Pursuant to 26 U.S.C. § 6324 (b), Plaintiff seeks to impose personal liability for tax deficiencies on Defendants as donees.”

United States v. Geniviva, 16 F.3d 522 (3rd Cir. 1994). · cites it 4× “Because a section 6901 assessment is not a prerequisite to an action against transferees under 26 U.S.C. § 6324 (a)(2) and this case was filed within the statutory period for claims under the latter section, we will affirm.”

United States v. Potemken, 841 F.2d 97 (4th Cir. 1988). · cites it 4× “The district court held that the special federal estate tax lien provided for in § 6324(a)(1) of the Internal Revenue Code of 1954, 26 U.S.C. § 6324 (a)(1), has an absolute duration of ten years from the decedent’s death, which period is not tolled by the government’s filing of…”

In Re Est. of Threefoot, 316 F. Supp. 2d 636 (W.D. Tenn. 2004). · cites it 4× “She also seeks a determination that the lien for federal estate taxes arising under 26 U.S.C. § 6324 (a)(1) applies to the partnership interest which is part of the decedent’s estate rather than to the property to be transferred to the partnership.”

William D. Kleine & Wife v. Ann Kleine, & Brown Oil Tools, Inc. v. United States, 539 F.2d 427 (5th Cir. 1976). · cites it 3× “Section 6324(a)(1) of the Internal Revenue Code of 1954, 26 U.S.C. § 6324 (a)(1), imposes a pre-assessment tax lien on the gross estate of any decedent whose proper *429 ty is subject to the estate tax.”

Adamowicz v. United States, 101 Fed. Cl. 485 (Fed. Cl. 2011). · cites it 2× “However, at the time of Mary Adamowicz’s death, the IRS pursuant to 26 U.S.C. § 6324 (a) automatically imposed a lien for unpaid estate taxes on all the assets of the estate.”

Prowse v. Walters, 941 S.W.2d 223 (Tex. App. 1997). · cites it 2× “Special Estate Tax Lien Under 26 U.S.C. § 6324 (a)(1), “the estate tax .”

In Re Est. of Jones, 796 A.2d 1003 (Pa. Super. Ct. 2002). “26 U.S.C. § 6324 (a)(2). ¶ 18 In conclusion, the tax clause of Gail’s will provided that all death taxes were to be paid out of the principal of her residuary estate, and, if anything remained in the residuary estate after satisfaction of the tax liability, it would pass to…”

United States v. Thomas H. Cleavenger, Adm'r of the Est. of Lurline B. (App) Smith, Deceased, & Ernest Rueth, Intervenor, 517 F.2d 230 (7th Cir. 1975). · cites it 2× “The court held that the special lien for estate taxes imposed by Section 6324(a)(1) of the Internal Revenue Code of 1954, 26 U.S.C. § 6324 (a)(1), 1 expired ten years after the death of the decedent notwithstanding that the Government had instituted an action to foreclose that…”

Est. of Armstrong v. United States, 277 F.3d 490 (4th Cir. 2002). · cites it 2× “26 U.S.C.A. § 6324 (a)(2), (b) (West 1989).”

Newport v. Michelin Aircraft Tire Corp., 851 F. Supp. 1406 (W.D. Mo. 1994). · cites it 5× “The United States is seeking in this lawsuit to foreclose an estate tax lien pursuant to 26 U.S.C. § 6324 (a)(1) on two parcels of real property originally belonging to the Estate of Edward F.”

United States Internal Revenue Serv. v. Vlavianos (In Re Vlavianos), 71 B.R. 789 (Bankr. W.D. Va. 1986). “Thus, the debtor was treating the IRS as a creditor by reason of her personal liability, arising pursuant to 26 U.S.C. § 6324 (a)(2) (1982) of the Internal Revenue Code, for the failure of her mother’s estate to pay the estate tax when due.”

Est. of Ruby Miller Whittle, Deceased, Citizens Nat'l Bank of Decatur, Tr. v. Comm'r of Internal Revenue, 994 F.2d 379 (7th Cir. 1993). “The Commissioner argues that under section 6324(a)(1) the interest was a lien on John’s property. The Tax Court recognized, however, that the obligation to pay tax on the value of John’s share of the joint tenancy .”

In re Spenlinhauer, 573 B.R. 343 (Bankr. D. Mass. 2017). “See also 26 U.S.C. § 6324 (a), and U.S. v. Valley Nat'l Bank (In re Decker), 199 B.”

Poinier v. Comm'r, 858 F.2d 917 (3rd Cir. 1988). · cites it 2× “While that is true, it is irrelevant, for 26 U.S.C. § 6324 (b) (1970) provides in relevant part, that: unless the gift tax imposed by chapter 12 is sooner paid in full or becomes unenforceable by reason of lapse of time, *920 such tax shall be a lien upon all gifts made during…”

United States v. Perrina, 877 F. Supp. 215 (D.N.J. 1994). “1994), the Third Circuit noted that “Leighton has never been overruled, either by the Court or by statute, and it is binding upon us” and held that a § 6901 assessment is not a prerequisite to an action against transferees under 26 U.S.C. § 6324 (a)(2), which imposes liability…”

United States v. Est. of Claude Beresford Pearce, 498 F.2d 847 (3rd Cir. 1974). “The dispute is over priority of liens. The action is in rem rather than quasi in rem since its sole object is foreclosure of an alleged lien.”

United States v. Blakeman, 750 F. Supp. 216 (N.D. Tex. 1990). · cites it 2×

A & B Steel Shearing & Processing, Inc. v. United States, 934 F. Supp. 254 (E.D. Mich. 1996). · cites it 2× “26 U.S.C. § 6324 In addition to the general lien under § 6321, the Government has a lien under 26 U.”

United States v. Evans, 513 F. Supp. 2d 825 (W.D. Tex. 2007).

United States v. Davenport, 327 F. Supp. 2d 725 (S.D. Tex. 2004). · cites it 3×

United States v. Bartlett, 186 F. Supp. 2d 875 (C.D. Ill. 2002).

Young v. Comm'r, 926 F.2d 1083 (11th Cir. 1991).

United States v. Chapel Chase Jt. Venture Inc., 753 F. Supp. 179 (D. Maryland 1990). · cites it 2×

United States v. Russell, 327 F. Supp. 632 (1971). · cites it 2×

Warner v. Wilkey, 307 N.E.2d 847 (Mass. App. Ct. 1974).

Sessler v. United States, 7 F.3d 1449 (9th Cir. 1993).

Cont'l Oil Co. v. United States, 326 F. Supp. 266 (S.D.N.Y. 1971).

United States v. Blakeman ex rel. Est. of Blakeman, 997 F.2d 1084 (5th Cir. 1992). · cites it 2×

Est. of Woll ex rel. Woll v. United States, 44 F.3d 464 (7th Cir. 1994).

Carmody v. Peck, 515 A.2d 669 (Conn. Super. Ct. 1986). · cites it 2×

Est. of Norman D. Weeden, Deceased, William F. Weeden v. Comm'r of Internal Revenue, 685 F.2d 1160 (9th Cir. 1982).

Est. of Starkey v. United States, 58 F. Supp. 2d 939 (S.D. Ind. 1999).

A&B Steel Shearing & Processing, Inc. v. United States, 174 F.R.D. 65 (E.D. Mich. 1997).

Ashton v. Josephine Bay Paul & C. Michael Paul Found., Inc., 918 F.2d 1065 (2d Cir. 1990).

Laurain v. United States, 579 F. Supp. 2d 991 (M.D. Tenn. 2008).

United States v. Cleavenger, 325 F. Supp. 871 (N.D. Ind. 1971). · cites it 2×

United States v. Allison (E.D. Cal. 2022). · cites it 6×

United States v. Marin (S.D.N.Y. 2020). · cites it 5×

United States v. Ringling (D.S.D. 2019). · cites it 5×

Anne (Sandy) Batchelor-Robjohns v. United States, 788 F.3d 1280 (11th Cir. 2015). · cites it 3×

Metro. Life Ins. Co. v. United States, 874 F.2d 1234 (8th Cir. 1989).

Skiba v. Internal Revenue Serv. (In Re Roth), 301 B.R. 451 (Bankr. W.D. Pa. 2003). · cites it 2× “The IRS posits that “[bjecause debtor converted the value of that stock to his own benefit by selling the underlying assets and using some of the proceeds for his personal benefit, equity requires that the lien attach to the assets of the corporation and the proceeds from their…”

Hudson City Sav. Inst. v. Drossos, 56 A.F.T.R.2d (RIA) 6491 (N.Y. App. Div. 1985). · cites it 3×

Sequoia Prop. & Equip., Ltd. P'ship v. United States, 100 F. App'x 638 (9th Cir. 2004).

United States v. Kulhanek, 755 F. Supp. 2d 659 (W.D. Pa. 2010). · cites it 7×

United States v. 3809 Crain Ltd. P'ship, 884 F.2d 138 (4th Cir. 1989).

Robert H. Northington, Tr. & the First Nat'l Bank of Midland, Texas v. The United States of Am., 475 F.2d 720 (1st Cir. 1973).

United States v. Est. of Young, 592 F. Supp. 1478 (E.D. Pa. 1984). · cites it 2×

United States v. Est. of Sidney Elson (D.N.J. 2019). · cites it 3×

Karst (D. Kan. 2026). · cites it 3×

United States v. Melman, 530 F.2d 790 (8th Cir. 1976).

United States v. Widtfeldt (D. Neb. 2019). · cites it 2×

United States v. The Est. of Lorraine M. Kelley (D.N.J. 2020). · cites it 2×

NE Acceptance Corp. v. USA (D.N.H. 1997). · cites it 5×

Ruza v. Est. of Ruza, 132 So. 2d 308 (Fla. 3d DCA 1961). “Sophie Ruza filed her appeal from the last mentioned order and asserts here that the order was error because the United States was barred by delay and failure to prosecute its claim against the grantees under the provisions of section 6324(b) of the Internal Revenue Code, 1954,…”

United States v. James Widtfeldt (8th Cir. 2020).

In re Kardash, 573 B.R. 257 (Bankr. M.D. Fla. 2017).

In re Ramirez, 575 B.R. 159 (Bankr. S.D. Tex. 2017).

United States v. Widtfeldt (D. Neb. 2020).

Coleman v. Internal Revenue Serv. (D. Maryland 2025).

United States v. Jones (D.D.C. 2026).

White v. Stults (In Re White), 174 B.R. 775 (Bankr. S.D. Ill. 1994). · cites it 2×

United States v. Davenport (5th Cir. 2007).

Est. of Edward A. Boyd by Julia H. Boyd & Michael E. Boyd, Co-Pers. Representatives v. Comm'r of Internal Revenue, 819 F.2d 170 (7th Cir. 1987).

Est. of J.P. Walker v. Dpt.of Revenue (Tenn. Ct. App. 1999).

Stammel Est., 12 Pa. D. & C.3d 212 (1979).

McGinness v. Comm'r, 83 F. Supp. 2d 889 (N.D. Ohio 1999).

United States v. Russell, 309 F. Supp. 617 (D. Kan. 1969).

— 26 U.S.C. § 6324(a)(1) — 1 case

Skiba v. Internal Revenue Serv. (In Re Roth), 301 B.R. 451 (Bankr. W.D. Pa. 2003). “The IRS posits that “[bjecause debtor converted the value of that stock to his own benefit by selling the underlying assets and using some of the proceeds for his personal benefit, equity requires that the lien attach to the assets of the corporation and the proceeds from their…”

— 26 U.S.C. § 6324(b) — 1 case

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