The Tax Division brings tax collection suits, including as cross-claims or counterclaims, at the request of the IRS, pursuant to 26 U.S.C. § 7401. Tax Division attorneys usually handle suits in which the government seeks to

1. • reduce to judgment assessments for unpaid federal taxes
2. • foreclose federal tax liens
3. • petition for judicial approval for seizure of a principal residence, as required by 26 U.S.C. § 6334(e)
4. • recover erroneous tax refunds pursuant to 26 U.S.C. § 7405
5. • obtain judgment against a person who failed to honor an internal revenue levy pursuant to 26 U.S.C. § 6332(d)(1)
6. • set aside a fraudulent conveyance
7. • obtain a judgment against a transferee
8. • obtain a judgment under 26 U.S.C. § 3505 for unpaid taxes against a person who provided net payroll financing
9. • take other necessary legal actions to collect outstanding federal taxes, including suits brought with reference to the Federal Priority Statute, 31 U.S.C. § 3713
10. • defend or bring actions under 31 U.S.C. § 3711(g)(4)(C) concerning FBAR penalties imposed for failure to report an interest in a foreign financial institution as required by 31 U.S.C. § 5314 and its implementing regulations

[updated February 2018] [cited in JM 6-2.000]