Failure to surrender property placed under distraint and levy.
Section 351
SEC. 351. Failure to surrender property placed under distraint and levy. — Any person having in his possession or under his control any property or rights to property, upon which a warrant of constructive distraint or of actual distraint and levy has been issued shall, upon demand by the Collector of Internal Revenue or any of his deputies executing such warrant, surrender such property or right to property to the Collector of Internal Revenue or any of his deputies, under such property or rights is, at the time of such demand, subject to an attachment or execution under any judicial process. Any person who fails or refuses to surrender any of such property or right shall be liable in his own person and estate to the Government in a sum equal to the value of the property or rights not so surrendered but not exceeding the amount of the taxes (including penalties and interest) for the collection of which such warrant has been issued, together with costs and interests, if any, from the date of such warrant. In addition, such person shall be punished by a fine of not more than three hundred pesos or by imprisonment for not more than six months or both