Limitation on enforcement of liens against principal residences

(a) In general Section 7403(a) of the Internal Revenue Code of 1986 is amended— (1) by striking In any case and inserting the following: (1) In general In any case; and (2) by adding at the end the following new paragraph: (2) Limitation with respect to principal residence (A) In general Paragraph (1) shall not apply to any property used as the principal residence of the taxpayer (within the meaning of section 121) unless the Secretary of the Treasury makes a written determination that— (i) all other property of the taxpayer, if sold, is insufficient to pay the tax or discharge the liability, and (ii) such action will not create an economic hardship for the taxpayer. (B) Delegation For purposes of this paragraph, the Secretary of the Treasury may not delegate any responsibilities under subparagraph (A) to any person other than— (i) the Commissioner of Internal Revenue, or (ii) a district director or assistant district director of the Internal Revenue Service.. (b) Effective date The amendments made by this section shall apply to actions filed after the date of the enactment of this Act.