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IRS issues final regulations (T.D. 9520) related to the validity and priority of federal tax liens against certain persons under tax code Section 6323. IRS says the proposed regulations contemplated amending Section 301.6323(g)-1(a)(3) to provide generally that, with respect to a notice of federal tax lien that includes a certificate of release, failure to timely refile the notice in any jurisdiction where it was originally filed extinguishes the lien.
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