The Federal Tax Lien attaches to all property and /or rights, title or interest in property, whether real or personal, tangible or intangible presently belonging to a taxpayer or acquired during the life of the lien. There are no exemptions in law.
The IRS Federal Tax Lien is the government's claim on taxpayer's property for the payment of a tax debt. By itself, it doesn't transfer or seize the property. Encumbered property can only be taken and sold after a separate levy or seizure action by the IRS.
Section 6321 of the IRC establishes a tax lien upon assessment of a tax liability when notice and demand is made upon the taxpayer and full payment is not made. IRS lien rights are no grater than the rights of the taxpayer.
Release of Lien:
IRC 7432 requires the IRS to release a Federal Tax Lien no later than 30 days after the liability is fully paid or the lien becomes legally unenforceable. Examples of unenforceable liens are:
IRC 7432 provides for a civil action for damages against IRS if the lien is not released after proper notice
The present Notice of Tax Lien (NFTL) form used by IRS is self-releasing. If the Service allows the NFTL to expire without refilling the lien, then the lien is released.
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