Code of the District of Columbia

Subchapter II. Liens.


§ 47–4421. Lien for taxes.

(a) If a person liable to pay a tax neglects or refuses to pay the tax after demand, the amount, including any interest, addition to tax, or assessable penalty, together with any costs that may accrue, shall be a lien in favor of the District of Columbia upon all property (including rights to property), whether real or personal, belonging to the person, and shall have the same effect as a lien created by judgment. The lien shall attach to all property (including rights to property) belonging to, or acquired by, the person at any time during the period of the lien.

(b) A disclaimer of a property interest does not invalidate a lien under this section.


(June 9, 2001, D.C. Law 13-305, § 405(b), 48 DCR 334; Mar. 2, 2007, D.C. Law 16-205, § 4, 53 DCR 9063.)

Section References

This section is referenced in § 42-407, § 47-4422, and § 47-4423.

Effect of Amendments

D.C. Law 16-205, designated existing text as subsec. (a), and added subsec. (b).


§ 47–4422. Period of lien.

The lien imposed by § 47-4421 shall be deemed to have arisen at the time the assessment is made, or if the tax return is not timely filed, on the due date of the tax return, and shall continue until the liability for the amount assessed (or a judgment against the taxpayer arising out of the liability) is satisfied or becomes unenforceable; provided, that:

(1) A lien for the tax imposed by Chapter 20 of this title or § 47-1812.08 shall arise on the due date of the tax return; and

(2) A lien for the taxes imposed by Chapter 37 of this title shall arise on the date of death.


(June 9, 2001, D.C. Law 13-305, § 405(b), 48 DCR 334.)


§ 47–4423. Lien priority.

(a) The lien imposed by § 47-4421 shall not be valid against a bona fide purchaser for value, holder of a security interest, mechanic’s lienor, or judgment lien creditor until the lien has been filed with the Recorder of Deeds.

(b) In the case of business property sold, transferred, or assigned in bulk other than in the ordinary course of trade or business, the purchaser shall also be deemed to have notice of taxes owing if the purchaser fails to give timely notice to the Mayor under § 47-4461.

(c) Notwithstanding subsection (a) of this section, the lien imposed by § 47-4421 for tax owing under Chapter 20 or § 47-1812.08 shall be valid against a purchaser, holder of a security interest, mechanic’s lienor, or judgment lien creditor regardless of when the lien is filed with the Recorder of Deeds; provided, that the lien shall not be valid against a bona fide purchaser for value of homestead real property.


(June 9, 2001, D.C. Law 13-305, § 405(b), 48 DCR 334; Apr. 4, 2003, D.C. Law 14-282, § 11(ggg), 50 DCR 896.)

Effect of Amendments

D.C. Law 14-282 rewrote the section which had read as follows: “Except for a lien for the tax imposed by Chapter 20 of this title or § 47-1812.08, the lien imposed by § 47-4421 shall not be valid as against a purchaser, holder of a security interest, mechanic’s lienor, or judgment lien creditor until the lien has been filed with the Recorder of Deeds.”

Emergency Legislation

For temporary (90 day) amendment of section, see § 12(ooo) of Tax Clarity and Recorder of Deeds Emergency Act of 2002 (D.C. Act 14-381, June 6, 2002, 49 DCR 5674).

For temporary (90 day) amendment of section, see § 12(ppp) of Tax Clarity and Related Amendments Emergency Act of 2002 (D.C. Act 14-456, July 23, 2002, 49 DCR 8107).

For temporary (90 day) amendment of section, see § 12(ppp) of Tax Clarity and Related Amendments Congressional Review Emergency Act of 2002 (D.C. Act 14-510, October 23, 2002, 49 DCR 10247).

Temporary Legislation

For temporary (225 day) amendment of section, see 12(ppp) of Tax Clarity and Recorder of Deeds Temporary Act of 2002 (D.C. Law 14-191, October 5, 2002, law notification 49 DCR 9549).

For temporary (225 day) amendment of section, see 12(ppp) of Tax Clarity and Related Amendments Temporary Act of 2003 (D.C. Law 14-228, March 23, 2003, law notification 50 DCR 2741).