26 U.S.C. § 6322
Section 6322 · Period of lien
Amended 2 times on record
Applied in 467 court decisions — leading case United States 77-1359 v. Kimbell Foods Inc (1979)
Most recently applied in McGimpsey v. D&L Ventures, Inc. (June 2019)
Applied most in the First Circuit Circuit (25 decisions)
Cases citing this section usually also cite 26 U.S.C. § 6321 · 26 U.S.C. § 6323 · 26 U.S.C. § 7403
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.
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.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Amendments
1966—Pub. L. 89–719 inserted “(or a judgment against the taxpayer arising out of such liability)”.
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.
Cross References
Action to enforce lien or to subject property to payment of tax, see section 7403 of this title.