US · guidance
Justice Manual § 6-5.120
Affirmative Litigation—Other Enforcement Suits
The Tax Division also brings other affirmative non-collection actions and claims seeking judicial assistance in enforcing the internal revenue laws. Such proceedings may include suits to
enjoin tax return preparers under 26 U.S.C. §§ 7402, 7407, and/or 7408
enjoin abusive scheme promoters under 26 U.S.C. § 7408
enjoin employers from pyramiding employment taxes or taxpayers from failing to pay estimated taxes, under 26 U.S.C. § 7402
expunge so-called "common law liens" filed against IRS or other government personnel, also under 26 U.S.C. § 7402
seeking a writ ne exeat
Tax Division attorneys will handle these proceedings.
History
[updated February 2018]
Provenance
- Source
- justice.gov
- Retrieved
- 2026-09-20
- Edition
- jm-2026-09-20
- Content hash
be7146972f7f14dbfe615adb56e9ffcdbb7ebb0d94a1251844dc4b7d21b58b18
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