Title 26, Internal Revenue CodeRelease 119-102
§6406 Prohibition of Administrative Review of Decisions
Title 26 › Subtitle F — Procedure and Administration › CHAPTER 65 — ABATEMENTS, CREDITS, AND REFUNDS › Subchapter A — Procedure in General › § 6406
Summary
The Secretary’s findings about facts and the decisions about any tax claim, including whether to allow interest on a credit or refund, cannot be reviewed by other federal administrative or accounting officers or employees. The only exceptions are if there was fraud, a mathematical error, or review is allowed under subchapters C and D of chapter 76 (relating to the Tax Court).
Full Legal Text
Title 26, §6406
Internal Revenue Code, Source: USLM XML via OLRC
In the absence of fraud or mistake in mathematical calculation, the findings of fact in and the decision of the Secretary upon the merits of any claim presented under or authorized by the internal revenue laws and the allowance or non-allowance by the Secretary of interest on any credit or refund under the internal revenue laws shall not, except as provided in subchapters C and D of chapter 76 (relating to the Tax Court), be subject to review by any other administrative or accounting officer, employee, or agent of the United States.
Legislative History
Notes & Related Subsidiaries
Editorial Notes
Amendments
1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary” wherever appearing.
Reference
Citations & Metadata
Citation
26 U.S.C. § 6406
Title 26, Internal Revenue Code
Last Updated
Aug 21, 2026
Release point: 119-102