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Justice Manual § 6-5.130

Affirmative Litigation—United States' Intervention in Court Actions to Enforce Tax Lien

activein force · 2018-02-01 – presentas-observed

The United States may intervene in a civil action to assert a federal tax lien on property that is the subject of the action. See 26 U.S.C. § 7424. Where the United States intervenes in a state court action, it has the same right of removal as in cases where it is named a party to an action under 28 U.S.C. § 2410(a).

If, under emergency circumstances, IRS counsel requests the United States Attorney’s Office to take immediate action to intervene in a pending action, the United States Attorney’s Office should not move to intervene until the Chief of the appropriate Civil Trial Section has approved the intervention.

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
d6adb1685d5f587e7ea955e41485801fba8128819c1115e27b80c61444bcec9c
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