26 CFR § 301.6532-3 - Periods of limitation on suits by persons other than taxpayers.

---
identifier: "/us/cfr/t26/s301.6532-3"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "26 CFR § 301.6532-3 - Periods of limitation on suits by persons other than taxpayers."
title_number: 26
title_name: "Internal Revenue"
section_number: "301.6532-3"
section_name: "Periods of limitation on suits by persons other than taxpayers."
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"
---


# 301.6532-3 Periods of limitation on suits by persons other than taxpayers.

(a) *General rule.* No suit or proceeding, except as otherwise provided in section 6532(c)(2) and paragraph (b) of this section, under section 7426 and § 301.7426-1 relating to civil actions by persons other than taxpayers, shall be begun after the expiration of 9 months from the date of levy or agreement under section 6325(b)(3) giving rise to such action.

(b) *Period when claim is filed.* The 9-month period prescribed in section 6532(c)(1) and paragraph (a) of this section shall be extended to the shorter of,

(1) 12 months from the date of filing by a third party of a written request under § 301.6343-1(b)(2) for the return of property wrongfully levied upon, or

(2) 6 months from the date of mailing by registered or certified mail by the district director to the party claimant of a notice of disallowance of the part of the request to which the action relates. A request which, under § 301.6343-1(b)(3), is not considered adequate does not extend the 9-month period described in paragraph (a) of this section.

(c) *Examples.* The provisions of this section may be illustrated by the following examples:

[T.D. 7305, 39 FR 9950, Mar. 15, 1974]