Can the IRS seize property held in the non-debtor’s name?

Yes, they can in certain circumstances.  If person A has a tax debt and transfers his property to person B for less than fair market value, the IRS can void that transfer through a court action.  This is pursued under the Statute of Frauds.  That statute states that when you transfer property after you have notice of a potential lawsuit or debt, the Court can reverse the transfer as being done to avoid the debt.  In addition, a recent Tax Court case held that property held by an “alter ego” or nominee of the taxpayer can be seized and sold for the taxes.  In other words, the sale is treated as a sham. The seizure and sale of the property can still probably be stopped if the taxpayer-debtor becomes proactive through an Installment Agreement, Offer in Compromise, etc.