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Under the law, once a tax lien (specifically) is choate all title to the property of the taxpayer legally inures to the lien holder and the race is on to recover the assets in order to satisfy the lien.

That means technically that all of the assets of the tax payer become the property of the taxing authority until the lien is satisfied. So if the tenant is paying rent to you after the lien is choate, that tenant is essentially paying the rent with the lien holder’s money and they have the legal right to get it back. Guess who they are going to take it from — the landlord!