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Title 28, Judiciary and Judicial ProcedureRelease 119-73not60

§1509 No Jurisdiction in Cases Involving Refunds of Tax Shelter Promoter and Understatement Penalties

Title 28 › Part IV— JURISDICTION AND VENUE › Chapter 91— UNITED STATES COURT OF FEDERAL CLAIMS › § 1509

Last updated Apr 5, 2026|Official source

Summary

The United States Court of Federal Claims cannot hear cases seeking refunds or credits of penalties under IRC sections 6700 or 6701.

Full Legal Text

Title 28, §1509

Judiciary and Judicial Procedure, Source: USLM XML via OLRC

The United States Court of Federal Claims shall not have jurisdiction to hear any action or proceeding for any refund or credit of any penalty imposed under section 6700 of the Internal Revenue Code of 1986 (relating to penalty for promoting abusive tax shelters, etc.) or section 6701 of such Code (relating to penalties for aiding and abetting understatement of tax liability).

Legislative History

Notes & Related Subsidiaries

Editorial Notes

References in Text

section 6700 and 6701 of the Internal Revenue Code of 1986, referred to in text, are classified to section 6700 and 6701, respectively, of Title 26, Internal Revenue Code.

Amendments

1992—Pub. L. 102–572 substituted “United States Court of Federal Claims” for “United States Claims Court”. 1986—Pub. L. 99–514 substituted “Internal Revenue Code of 1986” for “Internal Revenue Code of 1954”.

Statutory Notes and Related Subsidiaries

Effective Date

of 1992 AmendmentAmendment by Pub. L. 102–572 effective Oct. 29, 1992, see section 911 of Pub. L. 102–572, set out as a note under section 171 of this title.

Effective Date

Pub. L. 98–369, div. A, title VII, § 714(g)(4), July 18, 1984, 98 Stat. 962, provided that: “The

Amendments

made by this subsection [enacting this section and amending section 7422 of Title 26, Internal Revenue Code] shall apply to any claim for refund or credit filed after the date of the enactment of this Act [July 18, 1984].”

Reference

Citations & Metadata

Citation

28 U.S.C. § 1509

Title 28, Judiciary and Judicial Procedure

Last Updated

Apr 5, 2026

Release point: 119-73not60