Title 26 — Internal Revenue CodeRelease 119-73
§6326 Administrative Appeal of Liens
Title 26 › Subtitle Subtitle F— Procedure and Administration › Chapter 64— COLLECTION › Subchapter C— Lien for Taxes › Part II— LIENS › § 6326
Summary
If the IRS files a notice of a tax lien against your property and you believe the filing was a mistake, you can appeal to the IRS and ask for the lien to be released. If the IRS agrees the notice was filed in error, it must quickly issue a certificate releasing the lien, within 14 days of that decision when practical, and the certificate must state that the filing was erroneous.
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