The Internal Revenue Code authorizes the IRS to issue liens against delinquent taxpayers to protect the governments interest in the taxpayer's assets. This provision has been amended over and over since 1976, and the IRS has finally issued final regulations to reflect 35 years of changes.
Most federal tax liens contain self executing release dates. If the Service does not refile in time, the lien is automatically released. Under the new regulations, if the Service fails to refile a lien after it has begun litigation or levy procedings, the automatic release does not affect the Service's rights in the litigation or proceeding.
The new regulations also provided limited exceptions to federal tax liens for casual sales of personal property and some mechanic's liens.