Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 66-63

1966-1 C.B. 287

Full Text

Rev. Rul. 66-63 /1/

In view of the legislative history behind the adoption of the Revised Uniform Federal Tax Lien Registration Act in effect in Massachusetts, the Internal Revenue Service will consider the validity of the provisions of the law relating to real property separately from those relating to personal property.

Accordingly, since the Service has no objections to the provisions of Massachusetts law which require that liens against real property be filed with the register of deeds of the county where the real property is situated, notice of Federal tax lien against real property in the State of Massachusetts will no longer be filed with the clerk of the United States district court, and persons who have occasion to search for such notices will only have to search the office of the register of deeds where the real property is situated.

However, notice of Federal tax lien against personal property will continue to be filed with the clerk of the United States district court for the judicial district in which the taxpayer is domiciled. In addition, solely for the convenience of persons who have occasion to search, the Service will file a notice of such lien against personal property in the office of the clerk of the city or town in which the taxpayer is domiciled.

Revenue Ruling 64-170, C.B. 1964-1 (Part 1), 499, and Revenue Ruling 64-252, C.B. 1964-2, 497, which provide that the notices of Federal tax lien with respect to real property will be filed with the clerk of the United States district court in the judicial district in which the property is physically located, are modified insofar as they relate to real property in the State of Massachusetts.

/1/ Based on Technical Information Release 791, dated December 22, 1965.