republic-os/legal/us/code/title-26/chapter-66/section-6532.md

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LegalText	26 U.S.C. § 6532	Periods of limitation on suits	us	united_states_code	code_section	26	INTERNAL REVENUE CODE	66	LIMITATIONS	6532	26 U.S.C. § 6532	current	119-100	2026-06-26	official	https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip	/us/usc/t26/s6532	data/legal/raw/us/code/title-26/usc26.xml	390551e1b8c18f5f5938eb0f63b1e825aab84dfe0a8ecb9449042189bc9cdc45	a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4	5d43977736a6f43ce5ec42ef7e2d9d2259553df01480a529cbfc0fbf72c4bcf5	2026-07-04	official	legal us-code

26 U.S.C. § 6532 - Periods of limitation on suits

Text

(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 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.

(Aug. 16, 1954, ch. 736, 68A Stat. 816; Pub. L. 85–866, title I, § 89(b), Sept. 2, 1958, 72 Stat. 1665; Pub. L. 89–719, title I, § 110(b), Nov. 2, 1966, 80 Stat. 1144; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834; Pub. L. 96–589, § 6(d)(4), Dec. 24, 1980, 94 Stat. 3408; Pub. L. 115–97, title I, § 11071(b), Dec. 22, 2017, 131 Stat. 2091.)

Notes

Editorial Notes

Amendments2017—Subsec. (c)(1). Pub. L. 115–97, § 11071(b)(1), substituted “2 years” for “9 months”. Subsec. (c)(2). Pub. L. 115–97, § 11071(b)(2), substituted “2-year” for “9-month”. 1980—Subsec. (a)(5). Pub. L. 96–589 added par. (5). 1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary” wherever appearing. 1966—Subsec. (c). Pub. L. 89–719 added subsec. (c). 1958—Subsec. (a)(1), (4). Pub. L. 85–866 inserted “certified mail or” before “registered mail” wherever appearing.

Statutory Notes and Related Subsidiaries

Effective Date of 2017 AmendmentAmendment by Pub. L. 115–97 applicable to levies made after Dec. 22, 2017, and levies made on or before Dec. 22, 2017, if the 9-month period has not expired under section 6343(b) of this title (without regard to section 11071 of Pub. L. 115–97) as of such date, see section 11071(c) of Pub. L. 115–97, set out as a note under section 6343 of this title.

Effective Date of 1980 AmendmentAmendment by Pub. L. 96–589 effective Oct. 1, 1979, but not applicable to proceedings under Title 11, Bankruptcy, commenced before Oct. 1, 1979, see section 7(e) of Pub. L. 96–589, set out as a note under section 108 of this title.

Effective Date of 1966 AmendmentAmendment by Pub. L. 89–719 applicable after Nov. 2, 1966, 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 Pub. L. 89–719, set out as a note under section 6323 of this title.

Effective Date of 1958 AmendmentAmendment by Pub. L. 85–866 applicable only if mailing occurs after Sept. 2, 1958, see section 89(d) of Pub. L. 85–866, set out as a note under section 7502 of this title.