8.01-573, which gives third parties claiming an interest in attached property the right to intervene. Thus, the plaintiff has not taken advantage of § 2410’s waiver of sovereign immunity. Nor is he required to do so, even assuming that the United States is a senior lienholder. The Virginia statute on joining lienholders is permissive: “There may also be made a defendant any person claiming ... a lien upon the property sought to be attached.” Va.Code § 8.01-539 (emphasis added). Likewise, 28 U.S.C. § 2410 is not mandatory — it permits but does not require joinder of the United States. United States v. Brosnan, 363 U.S. 237 at 246, 80 S.Ct. 1108 at 1114, 4 L.Ed.2d 1192 compare United States v. Bluhm, 414 F.2d 1240, 1243 (7th Cir.1969), cert. den. 397 U.S. 910, 90 S.Ct. 909, 25 L.Ed.2d 91 (<HOLDING>). The government is correct that as a matter of
holding that a lien holder who is not served and joined as a party to a tax suit cannot have his lien extinguished by the tax sale holding that sovereign immunity does not bar extinguishment of united states junior lien in proceeding in which united states was not a party holding that when the united states held a senior tax lien it was an indispensable party under the controlling federal tax law holding that the tax was indirect even though the recipient could not shift the tax to others holding that interest received by a foreign corporation on a tax refund from the united states was interest on an interestbearing obligation of a resident of the united states within income tax statute