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26 CFR § 301.6532-2 - Periods of limitation on suits by the United States.

---
identifier: "/us/cfr/t26/s301.6532-2"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "26 CFR § 301.6532-2 - Periods of limitation on suits by the United States."
title_number: 26
title_name: "Internal Revenue"
section_number: "301.6532-2"
section_name: "Periods of limitation on suits by the United States."
chapter_name: "INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY"
subchapter_number: "F"
subchapter_name: "PROCEDURE AND ADMINISTRATION"
part_number: "301"
part_name: "PROCEDURE AND ADMINISTRATION"
positive_law: false
currency: "2026-03-24"
last_updated: "2026-03-24"
format_version: "1.1.0"
generator: "[email protected]"
authority: "26 U.S.C. 7805."
regulatory_source: "32 FR 15241, Nov. 3, 1967, unless otherwise noted."
cfr_part: "301"
---

# 301.6532-2 Periods of limitation on suits by the United States.

The United States may not recover any erroneous refund by civil action under section 7405 unless such action is begun within 2 years after the making of such refund. However, if any part of the refund was induced by fraud or misrepresentation of a material fact, the action to recover the erroneous refund may be brought at any time within 5 years from the date the refund was made.