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... shall be a lien in favor of the United States upon all property and rights to property, whether real or personal, belonging to such person.

Treasury Decisions Under Internal Revenue Laws of the United States - Page 238
by United States. Internal Revenue Service - 1926
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Federal Estate & Gift Taxes: Code & Regulations (Including Related Income ...

CCH Incorporated, CCH Tax Law Editors - Business & Economics - 2008 - 1632 pages

...of property. Sec. 6326. Administrative appeal of liens. * * * [Sec. 6321] SEC. 6321. LIEN FOR TAXES. If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount (including any interest, additional amount, addition to tax, or assessable penalty, together with any...

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