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question was filed on Form 668(Y) and bears a facsimile
signature.
Petitioner’s reliance on Nevada State law in this matter is
misplaced. It is well settled that the form and content of a
Notice of Federal Tax Lien is controlled by Federal law. United
States v. Union Cent. Life Ins. Co., 368 U.S. 291, 294 (1961).
In this regard, section 6323(f)(3) provides:
(3) Form.–-The form and content of the notice
referred to in subsection (a) shall be prescribed by
the Secretary. Such notice shall be valid
notwithstanding any other provision of law regarding
the form or content of a notice of lien.
Consistent with section 6323(f)(3), section 301.6323(f)-
1(d)(1), Proced. & Admin. Regs., provides:
(d) Form--(1) In general. The notice referred to
in �301.6323(a)-(1) shall be filed on Form 668, “Notice
of Federal Tax Lien under Internal Revenue Laws”. Such
notice is valid notwithstanding any other provision of
law regarding the form or content of a notice of lien.
For example, omission from the notice of lien of a
description of the property subject to the lien does
not affect the validity thereof even though State law
may require that the notice contain a description of
the property subject to the lien.
Based upon the plain language of section 6323(f)(3) and the
underlying regulation (quoted above), we hold that the Notice of
4(...continued)
Certification of notices of liens, certificates or
other notices affecting federal liens by the Secretary
of the Treasury of the United States or his delegate
* * * entitles them to be filed and no other
attestation, certification or acknowledgment is
necessary.
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