CODIFICATION OF INTERNAL REVENUE LAWS SEC. 3675. EFFECT OF CERTIFICATES OF RELEASE OR PARTIAL DIS- CHARGE. A certificate of release or of partial discharge issued under this sub- chapter shall be held conclusive that the lien upon the property cov- ered by the certificate is extinguished. SEC. 3676. SINGLE BOND COVERING RELEASE OF LIEN AND PAYMENT OF INCOME TAX DEFICIENCY. The Commissioner, with the approval of the Secretary, may by regulation provide for the acceptance of a single bond complying both with the requirements of section 272 (j) (relating to the exten- sion of time for the payment of a deficiency) and the requirements of subsection (b) of section 3673. SEC. 3677. EXTENDED APPLICATION OF PROVISIONS RELATING TO RELEASE OR PARTIAL DISCHARGE. Sections 3673, 3674, 3675, and 3676 shall apply to a lien in respect of any internal revenue tax, whether or not the lien is imposed by this subchapter. SEC. 3678. CIVIL ACTION TO ENFORCE LIEN ON PROPERTY. (a) FaNG. --In any case where there has been a refusal or neglect to pay any tax, and it has become necessary to seize and sell property and rights to property, whether real or personal, to satisfy the same, whether distraint proceedings have been commenced or not, the At- torney General at the request of the Commissioner may direct a civil action to be filed in a district court of the United States, to enforce the lien of the United States for tax upon any property and rights to property, whether real or personal, or to subject any such prop- erty and rights to property owned by the delinquent, or in which he has any right, title, or interest, to the payment of such tax. (b) PARTIES TO PRocEEDINos.-A ll persons having liens upon or claiming any interest in the property or rights to property sought to be subjected as aforesaid shall be made parties to such proceedings and be brought into court. (c) ADJUDICATION AND DECREE. -T he said court shall, at the term next after the parties have been duly notified of the proceedings, unless otherwise ordered by the court, proceed to adjudicate all mat- ters involved therein and finally determine the merits of all claims to and liens upon the property and rights to property in question, and, in all cases where a claim or interest of the United States therein is established, may decree a sale of such property and rights to property, by the proper officer of the court, and a distribution of the proceeds of such sale according to the findings of the court in respect to the interests of the parties and of the United States. (d) RECETVEBSHIP.- In any such proceeding, at the instance of the United States, the court may appoint a receiver to enforce the lien or, upon certification by the Commissioner during the pendency of such proceedings that it is in the public interest, may appoint a re- ceiver with all the powers of a receiver in equity. SEC. 3679. CIVIL ACTION TO CLEAR TITLE TO REALTY. (a) OBTAINING LEAVE TO FIe- (1) REQUEST FOR INSTITUTION OF PROCEEDINGS BY uNITED STATES.- Any person having a lien upon or any interest in the real estate referred to in section 3678, notice of which has been duly filed of record in the jurisdiction in which the real estate is located, prior to the filing of notice of the lien of the United States as pro- vided in section 3672, or any person purchasing the real estate at a sale to satisfy such prior lien or interest, may make written request to the Commissioner to authorize the filing of a civil action as provided in section 3678. (2) PEmITION To ooITtr. - If the Commissioner fails to authorize the filing of such civil action within six months after receipt of 450
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