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Title 26 — Internal Revenue CodeRelease 119-73

§6326 Administrative appeal of liens

Title 26 › Subtitle Subtitle F— - Procedure and Administration › Chapter CHAPTER 64— - COLLECTION › Subchapter Subchapter C— - Lien for Taxes › Part PART II— - LIENS › § 6326

Last updated Apr 6, 2026|Official source

Summary

If a lien notice is filed on your property or your rights in property, you can appeal to the Secretary for a release if you say the notice was filed by mistake. You must use the form and follow the time limits the Secretary’s rules set. If the Secretary agrees the notice was wrong, the Secretary must quickly issue a certificate saying the lien is released and that the filing was erroneous, and, when possible, do this within 14 days of the decision.

Full Legal Text

Title 26, §6326

Internal Revenue Code — Source: USLM XML via OLRC

(a)In such form and at such time as the Secretary shall prescribe by regulations, any person shall be allowed to appeal to the Secretary after the filing of a notice of a lien under this subchapter on the property or the rights to property of such person for a release of such lien alleging an error in the filing of the notice of such lien.
(b)If the Secretary determines that the filing of the notice of any lien was erroneous, the Secretary shall expeditiously (and, to the extent practicable, within 14 days after such determination) issue a certificate of release of such lien and shall include in such certificate a statement that such filing was erroneous.

Legislative History

Notes & Related Subsidiaries

Editorial Notes

Prior Provisions

A prior section 6326 was renumbered 6327 of this title.

Statutory Notes and Related Subsidiaries

Effective Date

Pub. L. 100–647, title VI, § 6238(d), Nov. 10, 1988, 102 Stat. 3743, provided that: “The

Amendments

made by this section [enacting this section] shall take effect on the date which is 60 days after the date

Regulations

are issued under subsection (b) [set out below].”

Regulations

Pub. L. 100–647, title VI, § 6238(b), Nov. 10, 1988, 102 Stat. 3743, required Secretary of the Treasury or Secretary’s delegate to prescribe

Regulations

necessary to implement administrative appeal provided for in amendment made by subsection (a) [enacting this section] within 180 days after Nov. 10, 1988.

Reference

Citations & Metadata

Citation

26 U.S.C. § 6326

Title 26 — Internal Revenue Code

Last Updated

Apr 6, 2026

Release point: 119-73