Provisional attachment permits interim seizure of taxpayer property, including bank accounts, to protect revenue during assessment proceedings. The Commissioner may, by written order, provisionally attach any property, including bank accounts, of a taxable person during specified pending assessment or recovery proceedings when necessary to protect Government revenue; such provisional attachment is an interim, time limited revenue protective measure that ceases to have effect after the prescribed limited period from the date of the order.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Provisional attachment permits interim seizure of taxpayer property, including bank accounts, to protect revenue during assessment proceedings.
The Commissioner may, by written order, provisionally attach any property, including bank accounts, of a taxable person during specified pending assessment or recovery proceedings when necessary to protect Government revenue; such provisional attachment is an interim, time limited revenue protective measure that ceases to have effect after the prescribed limited period from the date of the order.
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