IRC 6321 – Federal Tax Lien

IRC 6321 establishes that if any person liable to pay a tax neglects or refuses to pay after demand the amount owedincluding any interest additional amounts additions to tax assessable penalties and any accruing costsbecomes a lien in favor of the United States This lien attaches to all property and rights to property whether real or personal belonging to the taxpayer The lien arises automatically by operation of law once the following conditions are met The IRS has made an assessment of the tax liability The IRS has made a demand for payment The taxpayer has neglected or refused to pay the liability after demand The lien covers both current and future property and rights to property acquired by the taxpayer during the period the lien is in effect The lien continues until the liability is satisfied or becomes unenforceable due to the lapse of time statute of limitations