Reg. § 301.6323(a)-1 Purchasers, holders of security interests, mechanic's lienors, and judgment lien creditors.

26 CFR § 301.6323(a)-1eCFR, current through 2026-07-14

(a) Invalidity of lien without notice The lien imposed by section is not valid against any purchaser (as defined in ), holder of a security interest (as defined in ), mechanic's lienor (as defined in ), or judgment lien creditor (as defined in ) until a notice of lien is filed in accordance with ). Except as provided by section , if a person becomes a purchaser, holder of a security interest, mechanic's lienor, or judgment lien creditor after a notice of lien is filed in accordance with , the interest acquired by such person is subject to the lien imposed by section .

(b) Cross references For provisions relating to the protection afforded a security interest arising after tax lien filing, which interest is covered by a commercial transactions financing agreement, real property construction or improvement financing agreement, or an obligatory disbursement agreement, see , , and , respectively. For provisions relating to the protection afforded to a security interest coming into existence by virtue of disbursements, made before the 46th day after the date of tax lien filing, see . For provisions relating to priority afforded to interest and certain other expenses with respect to a lien or security interest having priority over the lien imposed by section , see . For provisions relating to certain other interests arising after tax lien filing, see .

[T.D. 7429, 41 FR 35498, Aug. 23, 1976]