Transfer of property to defraud revenue is void against tax claims unless for adequate consideration and without notice.

A transfer or charge of property executed by a person after tax has become due, intended to defraud Government revenue, is void against claims for that tax or other sums payable. Transfers are invalid when made by sale, mortgage, exchange or any mode of transfer to defeat tax recovery. The voidability does not apply if the transfer was for adequate consideration and without notice of recovery proceedings or the tax due, or where prior permission of the proper officer was obtained.

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