Title 26, Internal Revenue CodeRelease 119-110
§6326 Administrative Appeal of Liens
Title 26 › Subtitle F — Procedure and Administration › CHAPTER 64 — COLLECTION › Subchapter C — Lien for Taxes › PART II — LIENS › § 6326
Summary
Allows anyone with a lien filed on their property to appeal to the Secretary for a release if they say the lien notice was filed in error, using the form and timing the Secretary sets. If the Secretary finds the filing was wrong, the Secretary must promptly issue a certificate saying the lien is released and that the filing was erroneous, and should do so within 14 days when possible.
Full Legal Text
Title 26, §6326
Internal Revenue Code, Source: USLM XML via OLRC
(a)In general
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)Certificate of release
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
Sep 22, 2026
Release point: 119-110