Can the IRS seize property in a non-liable taxpayer’s name?

Yes they can for two reasons. First the Statute of Frauds states that when one transfers property after he has 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. In that case the entertainer Sinbad was the delinquent taxpayer and owed more than $8 million to the IRS.