26 U.S.C. § 6321
Section 6321 · Lien for taxes
Amended 1 time on record
Applied in 1,566 court decisions — leading case United States v. Whiting Pools, Inc. (1983)
Most recently applied in Ronald Morgan v. Daniel Bruton (April 2024)
Applied most in the Ninth Circuit Circuit (75 decisions)
Cases citing this section usually also cite 26 U.S.C. § 6323 · 26 U.S.C. § 6322 · 26 U.S.C. § 6331
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
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.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Short Title
Pub. L. 89–719, §1(a), Nov. 2, 1966, 80 Stat. 1125, provided that: “This Act [enacting sections 3505, 7425, 7426, and 7810 of this title, amending sections 545, 6322 to 6325, 6331, 6332, 6334, 6335, 6337 to 6339, 6342, 6343, 6502, 6503, 6532, 7402, 7403, 7421, 7424, 7505, 7506, and 7809 of this title, sections 1346, 1402, and 2410 of Title 28, Judiciary and Judicial Procedure, and section 270a of Title 40, Public Buildings, Property, and Works, redesignating section 7425 as 7427 of this title, and enacting provisions set out as notes under sections 6323 and 7424 of this title, and under section 1346 of Title 28] may be cited as the ‘Federal Tax Lien Act of 1966’.”
Cross References
Action to enforce lien or to subject property to payment of tax, see section 7403 of this title.
Additions to tax and additional amounts generally, see section 6651 et seq. of this title.
Assessable penalties, see section 6671 et seq. of this title.
Interest on nonpayment of tax, see section 6601 of this title.
Notice and demand for tax, see section 6303 of this title.
Payment on notice and demand, see section 6155 of this title.