US · guidance
Justice Manual § 6-5.110
Affirmative Litigation—Tax Collection Suits
The Tax Division brings tax collection suits, including as cross-claims or counterclaims, at the request of the IRS, pursuant to 26 U.S.C. § 7401. Tax Division attorneys usually handle suits in which the government seeks to
reduce to judgment assessments for unpaid federal taxes
foreclose federal tax liens
petition for judicial approval for seizure of a principal residence, as required by 26 U.S.C. § 6334(e)
recover erroneous tax refunds pursuant to 26 U.S.C. § 7405
obtain judgment against a person who failed to honor an internal revenue levy pursuant to 26 U.S.C. § 6332(d)(1)
set aside a fraudulent conveyance
obtain a judgment against a transferee
obtain a judgment under 26 U.S.C. § 3505 for unpaid taxes against a person who provided net payroll financing
take other necessary legal actions to collect outstanding federal taxes, including suits brought with reference to the Federal Priority Statute, 31 U.S.C. § 3713
defend or bring actions under 31 U.S.C. § 3711(g)(4)(C) concerning FBAR penalties imposed for failure to report an interest in a foreign financial institution as required by 31 U.S.C. § 5314 and its implementing regulations
History
[updated February 2018] [cited in JM 6-2.000]
Provenance
- Source
- justice.gov
- Retrieved
- 2026-09-20
- Edition
- jm-2026-09-20
- Content hash
7b4d77d745ecc240ca1a4496bdb850348e60a42dc06b471df7dc7c6441d0fe12
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