# § 7421. Prohibition of suits to restrain assessment or collection
**(a)** **Tax** Except as provided in sections 6015(e), 6212(a) and (c), 6213(a), 6232(c), 6330(e)(1), 6331(i), 6672(c), 6694(c), 7426(a) and (b)(1), 7429(b), and 7436, no suit for the purpose of restraining the assessment or collection of any tax shall be maintained in any court by any person, whether or not such person is the person against whom such tax was assessed.
**(b)** **Liability of transferee or fiduciary** No suit shall be maintained in any court for the purpose of restraining the assessment or collection (pursuant to the provisions of chapter 71) of—
**(1)** the amount of the liability, at law or in equity, of a transferee of property of a taxpayer in respect of any internal revenue tax, or
**(2)** the amount of the liability of a fiduciary under section 3713(b) of title 31, United States Code, in respect of any such tax.
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**Source Credit**: (Aug. 16, 1954, ch. 736, 68A Stat. 876; Pub. L. 89–719, title I, § 110(c), Nov. 2, 1966, 80 Stat. 1144; Pub. L. 94–455, title XII, § 1204(c)(11), Oct. 4, 1976, 90 Stat. 1699; Pub. L. 95–628, § 9(b)(1), Nov. 10, 1978, 92 Stat. 3633; Pub. L. 97–258, § 3(f)(13), Sept. 13, 1982, 96 Stat. 1065; Pub. L. 105–34, title XII, §§ 1222(b)(1), 1239(e)(3), title XIV, § 1454(b)(2), Aug. 5, 1997, 111 Stat. 1019, 1028, 1057; Pub. L. 105–206, title III, § 3201(e)(3), July 22, 1998, 112 Stat. 740; Pub. L. 105–277, div. J, title IV, § 4002(c)(1), (f), Oct. 21, 1998, 112 Stat. 2681–906, 2681–907; Pub. L. 106–554, § 1(a)(7) [title III, §§ 313(b)(2)(B), 319(24)], Dec. 21, 2000, 114 Stat. 2763, 2763A–642, 2763A–647; Pub. L. 114–74, title XI, § 1101(f)(10), Nov. 2, 2015, 129 Stat. 638; Pub. L. 115–141, div. U, title IV, § 401(a)(324), Mar. 23, 2018, 132 Stat. 1199.)
## Editorial Notes
### Amendments
2018—Subsec. (b)(2). substituted “Code, in” for “Code in”.
2015—Subsec. (a). substituted “6232(c)” for “6225(b), 6246(b)”.
2000—Subsec. (a). inserted “6330(e)(1),” after “6246(b),” and substituted “6672(c)” for “6672(b)”.
1998—Subsec. (a). substituted “6015(e)” for “6015(d)” and inserted “6331(i),” after “6246(b),”.
inserted “6015(d),” after “sections”.
1997—Subsec. (a). , substituted “7429(b), and 7436” for “and 7429(b)”.
, inserted “6225(b),” after “6213(a),”.
, inserted “6246(b),” after “6213(a),”.
1982—Subsec. (b)(2). substituted “, United States Code” for “section 3467 of the Revised Statutes ()”.
1978—Subsec. (a). inserted references to sections 6672(b) and 6694(c).
1976—Subsec. (a). substituted “7426(a) and (b)(1), and 7429(b)” for “and 7426(a) and (b)(1)”.
1966—Subsec. (a). inserted reference to section 7426(a), (b)(1), and “by any person, whether or not such person is the person against whom such tax was assessed”.
## Statutory Notes and Related Subsidiaries
### Effective Date of 2015 Amendment
Amendment by applicable to returns filed for partnership taxable years beginning after , with certain exceptions, see , set out as an Effective Date note under .
### Effective Date of 1998 Amendments
Amendment by effective as if included in the provision of the Internal Revenue Service Restructuring and Reform Act of 1998, , to which such amendment relates, see , set out as a note under .
Amendment by applicable to any liability for tax arising after , and any liability for tax arising on or before such date but remaining unpaid as of such date, see , set out as a note under .
### Effective Date of 1997 Amendment
Amendment by applicable to partnership taxable years beginning after , see , as amended, set out as a note under .
Amendment by applicable to partnership taxable years ending after , see , set out as a note under .
Amendment by , effective , see , set out as a note under .
### Effective Date of 1978 Amendment
Amendment by applicable with respect to penalties assessed more than 60 days after , see , set out as a note under .
### Effective Date of 1976 Amendment
Amendment by applicable with respect to action taken under section 6851, 6861, or 6862 of this title where notice and demand takes place after , see , as amended, set out as a note under .
### Effective Date of 1966 Amendment
Amendment by applicable after , regardless of when title or lien of United States arose or when lien or interest of another person was acquired, with certain exceptions, see section 114(a)–(c) of , set out as a note under .
### Prohibition on Requests to Taxpayers To Give Up Rights To Bring Actions
> **“(a)** **Prohibition.—** No officer or employee of the United States may request a taxpayer to waive the taxpayer’s right to bring a civil action against the United States or any officer or employee of the United States for any action taken in connection with the internal revenue laws.
>
> **“(b)** **Exceptions.—** Subsection (a) shall not apply in any case where—
>
> **“(1)** a taxpayer waives the right described in subsection (a) knowingly and voluntarily; or
>
> **“(2)** the request by the officer or employee is made in person and the taxpayer’s attorney or other federally authorized tax practitioner (within the meaning of section 7525(a)(3)(A) of the Internal Revenue Code of 1986) is present, or the request is made in writing to the taxpayer’s attorney or other representative.”
, , , provided that: