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26 U.S.C. § 6532 — Periods of limitation on suits
Federal law — U.S. Code and appendices · legal_authorities
**(a) Suits by taxpayers for refund**
(1) **General rule** — No suit or proceeding under section 7422(a) for the recovery of any internal revenue tax, penalty, or other sum, shall be begun before the expiration of 6 months from the date of filing the claim required under such section unless the Secretary renders a decision thereon within that time, nor after the expiration of 2 years from the date of mailing by certified mail or registered mail by the Secretary to the taxpayer of a notice of the disallowance of the part of the claim to which the suit or proceeding relates.
(2) **Extension of time** — The 2-year period prescribed in paragraph (1) shall be extended for such period as may be agreed upon in writing between the taxpayer and the Secretary.
(3) **Waiver of notice of disallowance** — If any person files a written waiver of the requirement that he be mailed a notice of disallowance, the 2-year period prescribed in paragraph (1) shall begin on the date such waiver is filed.
(4) **Reconsideration after mailing of notice** — Any consideration, reconsideration, or action by the Secretary with respect to such claim following the mailing of a notice by certified mail or registered mail of disallowance shall not operate to extend the period within which suit may be begun.
(5) **Cross reference** — For substitution of 120-day period for the 6-month period contained in paragraph (1) in a title 11 case, see [section 505(a)(2) of title 11](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title11-section505/a/2&num=0&edition=prelim) of the United States Code.
**(b) Suits by United States for recovery of erroneous refunds** Recovery of an erroneous refund by suit under section 7405 shall be allowed only if such suit is begun within 2 years after the making
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Source file: Laws/federal/codes/united-states-code/title-26/section-6532-periods-of-limitation-on-suits--401c84a84f.md
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Source location: Title 26, Chapter 66, § 6532; chapter-066-limitations.md
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**(a) Suits by taxpayers for refund**
(1) **General rule** — No suit or proceeding under section 7422(a) for the recovery of any internal revenue tax, penalty, or other sum, shall be begun before the expiration of 6 months from the date of filing the claim required under such section unless the Secretary renders a decision thereon within that time, nor after the expiration of 2 years from the date of mailing by certified mail or registered mail by the Secretary to the taxpayer of a notice of the disallowance of the part of the claim to which the suit or proceeding relates.
(2) **Extension of time** — The 2-year period prescribed in paragraph (1) shall be extended for such period as may be agreed upon in writing between the taxpayer and the Secretary.
(3) **Waiver of notice of disallowance** — If any person files a written waiver of the requirement that he be mailed a notice of disallowance, the 2-year period prescribed in paragraph (1) shall begin on the date such waiver is filed.
(4) **Reconsideration after mailing of notice** — Any consideration, reconsideration, or action by the Secretary with respect to such claim following the mailing of a notice by certified mail or registered mail of disallowance shall not operate to extend the period within which suit may be begun.
(5) **Cross reference** — For substitution of 120-day period for the 6-month period contained in paragraph (1) in a title 11 case, see [section 505(a)(2) of title 11](https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title11-section505/a/2&num=0&edition=prelim) of the United States Code.
**(b) Suits by United States for recovery of erroneous refunds** Recovery of an erroneous refund by suit under section 7405 shall be allowed only if such suit is begun within 2 years after the making of such refund, except that such suit may be brought at any time within 5 years from the making of the refund if it appears that any part of the refund was induced by fraud or misrepresentation of a material fact.
**(c) Suits by persons other than taxpayers**
(1) **General rule** — Except as provided by paragraph (2), no suit or proceeding under section 7426 shall be begun after the expiration of 2 years from the date of the levy or agreement giving rise to such action.
(2) **Period when claim is filed** — If a request is made for the return of property described in section 6343(b), the 2-year period prescribed in paragraph (1) shall be extended for a period of 12 months from the date of filing of such request or for a period of 6 months from the date of mailing by registered or certified mail by the Secretary to the person making such request of a notice of disallowance of the part of the request to which the action relates, whichever is shorter.
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Federal law — U.S. Code and appendices · legal_authorities
**(a) General rule**
(1) **Date of delivery** — If any return, claim, statement, or other document required to be filed, or any payment required to be made, within a prescribed period or on or before a prescribed date under authority of any provision of the internal revenue laws is, after such period or such date, delivered by United States mail to the agency, officer, or office with which such return, claim, statement, or other document is required to be filed, or to which such payment is required to be made, the date of the United States postmark stamped on the cover in which such return, claim, statement, or other document, or payment, is mailed shall be deemed to be the date of delivery or the date of payment, as the case may be.
(2) **Mailing requirements** — This subsection shall apply only if—
(A) the postmark date falls within the prescribed period or on or before the prescribed date—
(i) for the filing (including any extension granted for such filing) of the return, claim, statement, or other document, or
(ii) for making the payment (including any extension granted for making such payment), and
(B) the return, claim, statement, or other document, or payment was, within the time prescribed in subparagraph (A), deposited in the mail in the United States in an envelope or other appropriate wrapper, postage prepaid, properly addressed to the agency, officer, or office with which the return, claim, statement, or other document is required to be filed, or to which such payment is required to be made.
**(b) Postmarks** This section shall apply in the case of postmarks not made by the United States Postal Service only if and to the extent provided by regulations prescribed by the Secretary.
**(c) Registered and certified mailing; electronic filing**
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 7502
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Release of levy and notice of release**
(1) **In general** — Under regulations prescribed by the Secretary, the Secretary shall release the levy upon all, or part of, the property or rights to property levied upon and shall promptly notify the person upon whom such levy was made (if any) that such levy has been released if—
(A) the liability for which such levy was made is satisfied or becomes unenforceable by reason of lapse of time,
(B) release of such levy will facilitate the collection of such liability,
(C) the taxpayer has entered into an agreement under section 6159 to satisfy such liability by means of installment payments, unless such agreement provides otherwise,
(D) the Secretary has determined that such levy is creating an economic hardship due to the financial condition of the taxpayer, or
(E) the fair market value of the property exceeds such liability and release of the levy on a part of such property could be made without hindering the collection of such liability.
For purposes of subparagraph (C), the Secretary is not required to release such levy if such release would jeopardize the secured creditor status of the Secretary.
(2) **Expedited determination on certain business property** — In the case of any tangible personal property essential in carrying on the trade or business of the taxpayer, the Secretary shall provide for an expedited determination under paragraph (1) if levy on such tangible personal property would prevent the taxpayer from carrying on such trade or business.
(3) **Subsequent levy** — The release of levy on any property under paragraph (1) shall not prevent any subsequent levy on such property.
**(b) Return of property** If the Secretary determines that property has been wrongfully levied upon, it shall b
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6343
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Exclusion from gross income**
(1) **In general** — Gross income does not include any amount which (but for this subsection) would be includible in gross income by reason of the discharge (in whole or in part) of indebtedness of the taxpayer if—
(A) the discharge occurs in a title 11 case,
(B) the discharge occurs when the taxpayer is insolvent,
(C) the indebtedness discharged is qualified farm indebtedness,
(D) in the case of a taxpayer other than a C corporation, the indebtedness discharged is qualified real property business indebtedness, or
(E) the indebtedness discharged is qualified principal residence indebtedness which is discharged—
(i) before January 1, 2026, or
(ii) subject to an arrangement that is entered into and evidenced in writing before January 1, 2026.
(2) **Coordination of exclusions**
(A) *Title 11 exclusion takes precedence* — Subparagraphs (B), (C), (D), and (E) of paragraph (1) shall not apply to a discharge which occurs in a title 11 case.
(B) *Insolvency exclusion takes precedence over qualified farm exclusion and qualified real property business exclusion* — Subparagraphs (C) and (D) of paragraph (1) shall not apply to a discharge to the extent the taxpayer is insolvent.
(C) *Principal residence exclusion takes precedence over insolvency exclusion unless elected otherwise* — Paragraph (1)(B) shall not apply to a discharge to which paragraph (1)(E) applies unless the taxpayer elects to apply paragraph (1)(B) in lieu of paragraph (1)(E).
(3) **Insolvency exclusion limited to amount of insolvency** — In the case of a discharge to which paragraph (1)(B) applies, the amount excluded under paragraph (1)(B) shall not exceed the amount by which the taxpayer is insolvent.
**(b) Reduction of tax attributes**
(
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Purchasers, holders of security interests, mechanic’s lienors, and judgment lien creditors** The lien imposed by section 6321 shall not be valid as against any purchaser, holder of a security interest, mechanic’s lienor, or judgment lien creditor until notice thereof which meets the requirements of subsection (f) has been filed by the Secretary.
**(b) Protection for certain interests even though notice filed** Even though notice of a lien imposed by section 6321 has been filed, such lien shall not be valid—
(1) **Securities** — With respect to a security (as defined in subsection (h)(4))—
(A) as against a purchaser of such security who at the time of purchase did not have actual notice or knowledge of the existence of such lien; and
(B) as against a holder of a security interest in such security who, at the time such interest came into existence, did not have actual notice or knowledge of the existence of such lien.
(2) **Motor vehicles** — With respect to a motor vehicle (as defined in subsection (h)(3)), as against a purchaser of such motor vehicle, if—
(A) at the time of the purchase such purchaser did not have actual notice or knowledge of the existence of such lien, and
(B) before the purchaser obtains such notice or knowledge, he has acquired possession of such motor vehicle and has not thereafter relinquished possession of such motor vehicle to the seller or his agent.
(3) **Personal property purchased at retail** — With respect to tangible personal property purchased at retail, as against a purchaser in the ordinary course of the seller’s trade or business, unless at the time of such purchase such purchaser intends such purchase to (or knows such purchase will) hinder, evade, or defeat the collection of any tax under this title.
(4) **Pers
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Federal law — U.S. Code and appendices · legal_authorities
Page 3720
TITLE 26—INTERNAL REVENUE CODE
§ 6532
under the internal revenue laws unless the in-
dictment is found or the information instituted
within 3 years next after the commission of the
offense, except that the period of limitation
shall be 6 years—
(1) for offenses involving the defrauding or
attempting to defraud the United States or
any agency thereof, whether by conspiracy or
not, and in any manner;
(2) for the offense of willfully attempting in
any manner to evade or defeat any tax or the
payment thereof;
(3) for the offense of willfully aiding or as-
sisting in, or procuring, counseling, or advis-
ing, the preparation or presentation under, or
in connection with any matter arising under,
the internal revenue laws, of a false or fraudu-
lent return, affidavit, claim, or document
(whether or not such falsity or fraud is with
the knowledge or consent of the person au-
thorized or required to present such return, af-
fidavit, claim, or document);
(4) for the offense of willfully failing to pay
any tax, or make any return (other than a re-
turn required under authority of part III of
subchapter A of chapter 61) at the time or
times required by law or regulations;
(5) for offenses described in sections 7206(1)
and 7207 (relating to false statements and
fraudulent documents);
(6) for the offense described in section 7212(a)
(relating to intimidation of officers and em-
ployees of the United States);
(7) for offenses described in section 7214(a)
committed by officers and employees of the
United States; and
(8) for offenses arising under section 371 of
Title 18 of the United States Code, where the
object of the conspiracy is to attempt in any
manner to evade or defeat any tax or the pay-
ment thereof.
The time during which the person comm
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 6532
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