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The Liability

10 days after an assessment is made and the debt is unpaid, a statutory lien comes into existence via IRC §6321. This is a very powerful part of collections tax law. Congress wrote themselves out of many laws by the creation of this “Silent Lien”. This is an important IRM Cite:

5.12.1.2 (10-14-2013)
Introduction to Liens

Congress, through the Internal Revenue Code (IRC), has provided the IRS a powerful tool allowing the Government to protect the American taxpaying public’s interest in collecting the proper amount of tax revenues. This tool is the Federal tax lien (FTL) which is sometimes called the “statutory lien” or “assessment lien” . At times the lien has been referred to as the “silent” lien because, while the Service makes the taxpayer aware of the existence of the lien, it does not make the lien’s existence public unless a notice of the lien has been filed. Because the lien arises by operation of law, it is referred to throughout this IRM Chapter as the statutory lien or simply “lien” .
A federal tax lien is a claim against property including current and future rights to property. It represents the tax or tax related debt of an individual or business.
This IRM Section provides a broad outline or road map introducing liens, indicating where lien information can be found in the IRM 5.12 chapter, where lien information can be found in other IRM chapters, and providing contact points.
Title 26 of the United States Code is called the Internal Revenue Code (IRC). The legal cite might be seen referenced in a variety of ways including: 26 USC § 6321, IRC § 6321, IRC 6321, section 6321, and I.R.C. 6321 with or without the section symbol. The associated Treasury Regulation are found in the Code of Federal Regulations (CFR) and would be cited as Treas. Reg. § 301.6321-1 or as 26 CFR § 301.6321-1.
Both the Code and the Regulations have on-line research availability. Use the web pageUnited States Code on the US House of Representatives site or the web page Electronic Code of Federal Regulations on the National Archives and Records Administration site.
Though it may seem obvious, it is important to understand that a lien is not a levy. Information about levies can be found in IRM 5.11 and IRM 5.10.