# Pub. L. 89-719: changes to the Internal Revenue Code 1966-11-02, 80 Stat. 1132. Source: . ## Legislative history - Bill: [H.R. 11256](https://www.congress.gov/bill/89th-congress/house-bill/11256) ## § 545: Undistributed personal holding company income - § 545(b): Pub. L. 89–719 substituted “section 6323(f)” for “section 6323(a)(1), (2), or (3)”. ## § 3505: Liability of third parties paying or providing for wages - Enacted 26 U.S.C. § 3505. ## § 6322: Period of lien - § 6322: Pub. L. 89–719 inserted “(or a judgment against the taxpayer arising out of such liability)”. ## § 6323: Validity and priority against certain persons - § 6323(a): Pub. L. 89–719 redesignated as subsec. (a) that part of former subsec. (a) which preceded pars. (1) to (3) thereof, and, in subsec. (a) as so redesignated, substituted holder of a security interest, mechanic’s lienor, and judgment lien creditor for mortgagee, pledgee, and judgment creditor, struck out reference to an exception provided in subsecs. (c) and (d), and inserted reference to requirements of subsec. (f). - § 6323(b)(1): Pub. L. 89–719 redesignated provisions of subsec. (c)(1) as subsec. (b)(1) and substituted “holder of a security interest” for “mortgagee and pledgee” and purchaser of such security interest for purchaser of such security for any adequate and full consideration in money or money’s worth. - § 6323(b)(2): Pub. L. 89–719 redesignated provisions of subsec. (d)(1) as subsec. (b)(2) and substituted purchaser of such motor vehicle for purchaser of such motor vehicle for an adequate and full consideration in money or money’s worth and substituted actual notice or knowledge for notice or knowledge. - § 6323(b)(3), § 6323(b)(4), § 6323(b)(5), § 6323(b)(6), § 6323(b)(7), § 6323(b)(8), § 6323(b)(9), § 6323(b)(10): Pub. L. 89–719 added pars. (3) to (10). - § 6323(c), § 6323(d), § 6323(e): Pub. L. 89–719 added subsecs. (c) to (e). - § 6323(f)(1): Pub. L. 89–719 redesignated provisions of former subsec. (a)(1) to (3) as subsec. (f)(1). - § 6323(f)(2): Pub. L. 89–719 added par. (2). - § 6323(f)(3): Pub. L. 89–719 redesignated provisions of former subsec. (b) as subsec. (f)(3) and substituted provisions that the form and content of the notice be prescribed by the Secretary or his delegate for provisions limiting the effectiveness of the notice to situations in which the notice is in such form as would be valid if filed with the clerk of the United States district court when state or territory law fails to designate an office for the filing of notice. - § 6323(g): Pub. L. 89–719 added subsec. (g). - § 6323(h)(1), § 6323(h)(2): Pub. L. 89–719 added pars. (1) and (2). - § 6323(h)(3): Pub. L. 89–719 redesignated provisions of former subsec. (d)(2) as subsec. (h)(3). - § 6323(h)(4): Pub. L. 89–719 redesignated provisions of former subsec. (c)(2) as subsec. (h)(4). - § 6323(h)(5), § 6323(h)(6): Pub. L. 89–719 added pars. (5), (6). - § 6323(i)(1), § 6323(i)(2): Pub. L. 89–719 added pars. (1), (2). - § 6323(i)(3): Pub. L. 89–719 redesignated provisions of former subsec. (e) as subsec. (i)(3) and substituted “regulations” for “rules and relations”. ## § 6324: Special liens for estate and gift taxes - § 6324(a)(1): Pub. L. 89–719 inserted “, or becomes unenforceable by reason of lapse of time,” after “sooner paid in full” and substituted “10 years from the date of death” for “10 years upon the gross estate of the decedent”. - § 6324(a)(2): Pub. L. 89–719 substituted “person in possession, or beneficiary, to a purchaser or holder of a security interest” for “person in possession of property by reason of the exercise, nonexercise, or release of a power of appointment, or beneficiary, to a bona fide purchaser, mortgagee, or pledgee, for an adequate and full consideration in money and money’s worth” and “except any part transferred to a purchaser or a holder of a security interest” for “except any part transferred to a bona fide purchaser, mortgagee, or pledgee for an adequate and full consideration in money or money’s worth”. - § 6324(a)(3): Pub. L. 89–719 substituted “purchaser or a holder of a security interest” for “bona fide purchaser, mortgagee, or pledgee for an adequate and full consideration in money or money’s worth” and “purchaser or holder of a security interest” for “purchaser, mortgagee, or pledgee”. - § 6324(b): Pub. L. 89–719 substituted reference to exception provided in subsec. (c) for reference to exceptions provided in subsecs. (c) and (d), inserted reference to tax becoming unenforceable by reason of lapse of time, and substituted “purchaser or holder of a security interest” for “bona-fide purchaser, mortgagee, or pledgee, for an adequate and full consideration in money or money’s worth”. - § 6324(c): Pub. L. 89–719 redesignated as par. (1) provisions formerly constituting subsec. (c), substituted “valid as against a mechanic’s lienor and, subject to the conditions provided by section 6323(b) (relating to protection for certain interests even though noticed filed), shall not be valid with respect to any lien or interest described in section 6323(b)” for “valid with respect to a security, as defined in section 6323(c)(2), as against any mortgagee, pledgee, or purchaser of any such security, for an adequate and full consideration in money or money’s worth, if at the time of such mortgage, pledge, or purchase such mortgagee, pledgee, or purchaser is without notice or knowledge of the existence of such lien”, and added par. (2). - § 6324: Pub. L. 89–719 struck out subsec. (d) dealing with exceptions in the case of motor vehicles. See subsec. (c) above and reference therein to section 6323(b). ## § 6325: Release of lien or discharge of property - § 6325(b)(3): Pub. L. 89–719 added par. (3). - § 6325(d), § 6325(e): Pub. L. 89–719 added subsecs. (d) and (e). Former subsecs. (d) and (e) redesignated, with amendments, as subsecs. (f)(1) and (h), respectively. - § 6325(f): Pub. L. 89–719 redesignated as par. (1) provisions formerly constituting subsec. (d), inserted reference to exceptions provided in pars. (2) and (3) and reference to the filing of the certificate in the same office as the notice of lien to which it refers and expanded the types of certificates to include separate certificates of release, discharge, subordination, and nonattachment, and added pars. (2) and (3). - § 6325(g): Pub. L. 89–719 added subsec. (g). - § 6325(h): Pub. L. 89–719 redesignated as subsec. (h) provisions formerly constituting subsec. (e) and struck out cross references for single bonds, suits to enforce liens, and suits to clear title to realty. ## § 6331: Levy and distraint - § 6331(b): Pub. L. 89–719 inserted sentence providing that a levy shall extend only to property possessed and obligations existing at the time thereof. ## § 6332: Surrender of property subject to levy - § 6332(a): Pub. L. 89–719, § 104(b)(1), substituted “Except as otherwise provided in subsection (b), any person” for “Any person”. - § 6332(b): Pub. L. 89–719, § 104(b)(2), added subsec. (b). Former subsec. (b) redesignated, with amendments, as subsec. (c)(1). - § 6332(c): Pub. L. 89–719, § 104(b)(2)–(4), redesignated as par. (1) provisions formerly set out as subsec. (b), inserted provisions that any amount other than costs recovered under par. (1) shall be credited against the tax liability for the collection of which the levy was made, and added par. (2). Former subsec. (c) redesignated (e). - § 6332(d): Pub. L. 89–719, § 104(b)(4), added subsec. (d). - § 6332(e): Pub. L. 89–719, § 104(b)(3), redesignated former subsec. (c) as (e). ## § 6334: Property exempt from levy - § 6334(a)(4): Pub. L. 89–719, § 104(c)(1), struck out “or Territory” after “of any State”. - § 6334(a)(6), § 6334(a)(7): Pub. L. 89–719, § 104(c)(2), added pars. (6) and (7). ## § 6335: Sale of seized property - § 6335(b): Pub. L. 89–719 inserted an alternative to the publication of notice of sale to allow publication in a newspaper generally circulated within the county in which the property is seized even though the newspaper is not published in such county. ## § 6337: Redemption of property - § 6337(b)(1): Pub. L. 89–719 substituted “120 days” for “1 year”. ## § 6338: Certificate of sale; deed of real property - § 6338(c): Pub. L. 89–719 struck out provisions requiring the endorsement of approval as to the form of the deed by the United States Attorney for the district in which the property is situated. ## § 6339: Legal effect of certificate of sale of personal property and deed of real property - § 6339(c), § 6339(d): Pub. L. 89–719 added subsecs. (c) and (d). ## § 6342: Application of proceeds of levy - § 6342(a): Pub. L. 89–719 inserted in introductory provisions, references to an exception in the case of surrender under section 6332(c)(2) and to sale of property redeemed by the United States if the interest of the United States in such property was a lien arising under the provisions of this title, struck out “under this subchapter” after “proceedings” in par. (1), and inserted “or the sale was conducted” after “levy was made” in par. (3). ## § 6343: Authority to release levy and return property - § 6343: Pub. L. 89–719 inserted “and return property” in section catchline, designated existing provisions as subsec. (a), and added subsec. (b). ## § 6502: Collection after assessment - § 6502(a): Pub. L. 89–719 inserted sentence at end providing that the period provided by this subsection during which a tax may be collected by levy shall not be extended or curtailed by reason of a judgment against the taxpayer. ## § 6503: Suspension of running of period of limitation - § 6503(b): Pub. L. 89–719, § 106(a), struck out “(other than the estate of a decedent or of an incompetent)” after “assets of the taxpayer” and “or Territory” after “of any State”. - § 6503(c): Pub. L. 89–719, § 106(b), substituted “Taxpayer outside United States” for “Location of property outside the United States or removal of property from the United States” in heading, and “The running of the period of limitations on collection after assessment prescribed in section 6502 shall be suspended for the period during which the taxpayer is outside the United States if such period of absence is for a continuous period of at least 6 months. If the preceding sentence applies and at the time of the taxpayer’s return to the United States the period of limitations on collection after assessment prescribed in section 6502 would expire before the expiration of 6 months from the date of his return, such period shall not expire before the expiration of such 6 months” for “In case collection is hindered or delayed because property of the taxpayer is situated or held outside the United States or is removed from the United States, the period of limitations on collection after assessment prescribed in section 6502 shall be suspended for the period collection is so hindered or delayed. The total suspension of time under this subsection shall not in the aggregate exceed 6 years.” - § 6503(g): Pub. L. 89–719, § 106(c), added subsec. (g) and redesignated former subsec. (g) as (h). - § 6503(h): Pub. L. 89–719, § 106(c), redesignated former subsec. (g) as (h). ## § 6532: Periods of limitation on suits - § 6532(c): Pub. L. 89–719 added subsec. (c). ## § 7402: Jurisdiction of district courts - § 7402(e), § 7402(f): Pub. L. 89–719 added subsec. (e) and redesignated former subsec. (e) as (f). ## § 7403: Action to enforce lien or to subject property to payment of tax - § 7403(c): Pub. L. 89–719 inserted sentence permitting the United States, if the property is sold to satisfy a first lien held by the United States, to bid at the sale such sum, not more than the amount of such lien with expenses of sale, as the Secretary or his delegate directs. ## § 7421: Prohibition of suits to restrain assessment or collection - § 7421(a): Pub. L. 89–719 inserted reference to section 7426(a), (b)(1), and “by any person, whether or not such person is the person against whom such tax was assessed”. ## § 7424: Intervention - § 7424: 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. ## § 7425: Discharge of liens - Enacted 26 U.S.C. § 7425. ## § 7426: Civil actions by persons other than taxpayers - Enacted 26 U.S.C. § 7426. ## § 7437: Cross references ## § 7505: Sale of personal property acquired by the United States - § 7505: Pub. L. 89–719 substituted “acquired by the United States in payment of or as security for debts arising under the internal revenue laws” for “purchased by the United States under the authority of section 6335(e) (relating to purchase for the account of the United States of property sold under levy)” in subsec. (a), and substituted “acquired” for “purchased” in section catchline. ## § 7506: Administration of real estate acquired by the United States - § 7506(a): Pub. L. 89–719 inserted reference to real estate which has been redeemed by the United States. ## § 7809: Deposit of collections - § 7809(a), § 7809(b)(4): Pub. L. 89–719 inserted reference to section 7810 in subsec. (a) and added subsec. (b)(4). ## § 7810: Revolving fund for redemption of real property - Enacted 26 U.S.C. § 7810.