26 USC § 6326 - Administrative appeal of liens

---
identifier: "/us/usc/t26/s6326"
source: "usc"
legal_status: "official_prima_facie"
title: "26 USC § 6326 - Administrative appeal of liens"
title_number: 26
title_name: "INTERNAL REVENUE CODE"
section_number: "6326"
section_name: "Administrative appeal of liens"
chapter_number: 64
chapter_name: "COLLECTION"
subchapter_number: "C"
subchapter_name: "Lien for Taxes"
part_number: "II"
part_name: "LIENS"
positive_law: false
currency: "119-84"
last_updated: "2026-04-17"
format_version: "1.1.0"
generator: "[email protected]"
source_credit: "(Added Pub. L. 100–647, title VI, § 6238(a), Nov. 10, 1988, 102 Stat. 3743.)"
---


# § 6326. Administrative appeal of liens

**(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.

---

**Source Credit**: (Added Pub. L. 100–647, title VI, § 6238(a), Nov. 10, 1988, 102 Stat. 3743.)

## Editorial Notes

### Prior Provisions

A prior section 6326 was renumbered 6327 of this title.

## Statutory Notes and Related Subsidiaries

### Effective Date

> “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].”

, , , provided that:

### Regulations

, , , 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 .