Title 26Internal Revenue CodeRelease 119-73

§7424 Intervention

Title 26 › Subtitle Subtitle F— - Procedure and Administration › Chapter CHAPTER 76— - JUDICIAL PROCEEDINGS › Subchapter Subchapter B— - Proceedings by Taxpayers and Third Parties › § 7424

Last updated Apr 6, 2026|Official source

Summary

The United States may enter a civil suit it is not in to assert a lien under this title on property. When it joins, 28 U.S.C. 2410, except subsection (b), and 1444 apply as if the United States were a defendant; if intervention is denied, the suit can't affect the lien.

Full Legal Text

Title 26, §7424

Internal Revenue Code — Source: USLM XML via OLRC

If the United States is not a party to a civil action or suit, the United States may intervene in such action or suit to assert any lien arising under this title on the property which is the subject of such action or suit. The provisions of section 2410 of title 28 of the United States Code (except subsection (b)) and of section 1444 of title 28 of the United States Code shall apply in any case in which the United States intervenes as if the United States had originally been named a defendant in such action or suit. In any case in which the application of the United States to intervene is denied, the adjudication in such civil action or suit shall have no effect upon such lien.

Legislative History

Notes & Related Subsidiaries

Editorial Notes

Amendments

1966—Pub. L. 89–719 substituted “Intervention” for “Civil action to clear title to property” in section catchline and substituted provisions, set out in a single paragraph, granting the government authority to intervene in a court proceeding to assert any lien arising under this title on property which is the subject of a civil action or suit to which the government is not a party with the same procedural rules to apply as where the government is initially joined properly as a party and with the proceedings to have no effect on the government’s lien if the application to intervene is denied, for provisions, formerly set out in three subsections, setting out a procedure by which a person having a lien upon or interest in property referred to in section 7403 could file a civil action to clear title to the property and obtain an adjudication of the matter involved in the same manner as in the case of a civil action filed under section 7403.

Statutory Notes and Related Subsidiaries

Effective Date

of 1966 AmendmentAmendment by Pub. L. 89–719 applicable after Nov. 2, 1966, regardless of when the title or lien of the United States arose or when the lien or interest of another person was acquired, with certain exceptions, see section 114(a) to (c) of Pub. L. 89–719, set out as a note under section 6323 of this title. Civil Actions To Clear Title to Property Commenced Before Nov. 2, 1966 Pub. L. 89–719, title I, § 114(d), Nov. 2, 1966, 80 Stat. 1147, provided that civil actions commenced before Nov. 2, 1966, to clear title to property pursuant to this section as in effect before Nov. 2, 1966, were to be determined in accord with this section as in effect before Nov. 2, 1966.

Reference

Citations & Metadata

Citation

26 U.S.C. § 7424

Title 26Internal Revenue Code

Last Updated

Apr 6, 2026

Release point: 119-73