§301.6532-3. Periods of limitation on suits by persons other than taxpayers.
26 C.F.R. § 301.6532-3
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.
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,
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
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.
Examples. The provisions of this section may be illustrated by the following examples:
Notes, amendments, and revision history
Amendments
[T.D. 7305, 39 FR 9950, Mar. 15, 1974]
Authority
Authority: 26 U.S.C. 7805. Section 301.1474-1 also issued under 26 U.S.C. 1474(f). Section 301.6011-2 also issued under 26 U.S.C. 6011(e). Section 301.6011-3 also issued under 26 U.S.C. 6011. Section 301.6011-5 also issued under 26 U.S.C. 6011. Section 301.6011-6 also issued under 26 U.S.C. 6011(a). Section 301.6011-7 also issued under 26 U.S.C. 6011(e). Section 301.6011-10 also issued under 26 U.S.C. 6011. Section 301.6011-11 also issued under 26 U.S.C. 6011. Section 301.6011-12 also issued under 26 U.S.C. 6011. Section 301.6011-13 also issued under 26 U.S.C. 6011. Section 301.6011-14 also issued under 26 U.S.C. 6011. Section 301.6011-15 also issued under 26 U.S.C. 6011. Section 301.6012-2 also issued under 26 U.S.C. 6012. Section 301.6033-4 also issued under 26 U.S.C. 6033. Section 301.6036-1 also issued under 26 U.S.C. 6036. Section 301.6037-2 also issued under 26 U.S.C. 6037. Section 301.6039E-1 also issued under 26 U.S.C. 6039E. Section 301.6050M-1 also issued under 26 U.S.C. 6050M. Section 301.6057-3 also issued under 26 U.S.C. 6011 and 6057. Section 301.6058-2 also issued under 26 U.S.C. 6011 and 6058. Section 301.6059-2 also issued under 26 U.S.C. 6011 and 6059. Section 301.6061-1 also issued under 26 U.S.C. 6061. Section 301.6081-2 also issued under 26 U.S.C. 6081(a). Section 301.6103(c)-1 also issued under 26 U.S.C. 6103(c). Section 301.6103(h)(4)-1 also issued under 26 U.S.C. 6103(h)(4) and 26 U.S.C. 6103(q). Section 301.6103(j)(1)-1 also issued under 26 U.S.C. 6103(j)(1) and 6103(q). Section 301.6103(j)(5)-1 also issued under 26 U.S.C. 6103(j)(5). Section 301.6103(k)(6)-1 also issued under 26 U.S.C. 6103(k)(6); Section 301.6103(k)(6)-1T also issued under 26 U.S.C. 6103(k)(6); Section 301.6103(k)(9)-1 also issued under 26 U.S.C. 6103(k)(9) and 26 U.S.C. 6103(q). Section 301.6103(l)-1 also issued under 26 U.S.C. 6103(q). Section 301.6103(l)(14)-1 also issued under 26 U.S.C. 6103(l)(14). Section 301.6103(l)(21)-(1) also issued under 26 U.S.C. 6103(l)(21) and 6103(q). Section 301.6103(m)-1 also issued under 26 U.S.C. 6103(q). Section 301.6103(n)-1 also issued under 26 U.S.C. 6103(n). Section 301.6103(n)-2 also issued under 26 U.S.C. 6103(n). Section 301.6103(n)-2 also issued under 26 U.S.C. 6103(q). Section 301.6103(p)(2)(B)-1 also issued under 26 U.S.C. 6103(p)(2). Section 301.6103(p)(2)(B)-1T also issued under 26 U.S.C. 6103(p)(2). Sections 301.6103(p)(4)-1 and 301.6103(p)(7)-1T also issued under 26 U.S.C. 6103(p)(4) and (7) and (q), Section 301.6104(a)-6(d) is also issued under 5 U.S.C. 552. Section 301.6104(b)-1(d)(4) is also issued under 5 U.S.C. 552. Section 301.6104(c)-1 also issued under 26 U.S.C. 6104(c). Section 301.6104(d)-1(d)(3)(i) is also issued under 5 U.S.C. 552. Section 301.6104(d)-2 also issued under 26 U.S.C. 6104(d)(3). Section 301.6104(d)-3 also issued under 26 U.S.C. 6104(d)(3). Section 301.6104(d)-4 also issued under 26 U.S.C. 6104(e)(3). Section 301.6104(d)-5 also issued under 26 U.S.C. 6104(e)(3). Section 301.6109-1 also issued under 26 U.S.C. 6109 (a), (c), and (d). Section 301.6109-3 also issued under 26 U.S.C. 6109. Section 301.6111-1T also issued under 26 U.S.C. 6111. Section 301.6111-2T also issued under 26 U.S.C. 6111(f)(4). Section 301.6111-3 also issued under 26 U.S.C. 6111. Section 301.6111-3T also issued under 26 U.S.C. 6111. Section 301.6112-1T also issued under 26 U.S.C. 6112. Section 301.6114-1 also issued under 26 U.S.C. 6114. Section 301.6213-2 also issued under 26 U.S.C. 6213. Section 301.6221(a)-1 also issued under 26 U.S.C. 6221. Section 301.6221(b)-1 also issued under sections 6221 and 6241. Section 301.6222-1 also issued under 26 U.S.C. 6222 and 6223. Section 301.6222(a)-1T also issued under 26 U.S.C. 6230(k). Section 301.6222(a)-2T also issued under 26 U.S.C. 6230(k). Section 301.6222(b)-1T also issued under 26 U.S.C. 6230(k). Section 301.6222(b)-2T also issued under 26 U.S.C. 6230(k). Section 301.6222(b)-3T also issued under 26 U.S.C. 6230 (i) and (k). Section 301.6223(a)-1T also issued under 26 U.S.C. 6230(k). Section 301.6223(a)-2T also issued under 26 U.S.C. 6230(k). Section 301.6223(b)-1T also issued under 26 U.S.C. 6230 (i) and (k). Section 301.6223(b)-2T also issued under 26 U.S.C. 6230(k). Section 301.6223(c)-1T also issued under 26 U.S.C. 6223(c) and 6230 (i) and (k). Section 301.6223(e)-1T also issued under 26 U.S.C. 6230(k). Section 301.6223(e)-2T also issued under 26 U.S.C. 6230 (i) and (k). Section 301.6223(f)-1T also issued under 26 U.S.C. 6230(k). Section 301.6223(g)-1T also issued under 26 U.S.C. 6223(g) and 6230 (i) and (k). Section 301.6223(h)-1T also issued under 26 U.S.C. 6230 (i) and (k). Section 301.6224(a)-1T also issued under 26 U.S.C. 6230(k). Section 301.6224(b)-1T also issued under 26 U.S.C. 6230 (i) and (k). Section 301.6224(c)-1T also issued under 26 U.S.C. 6230 (i) and (k). Section 301.6224(c)-2T also issued under 26 U.S.C. 6230(k). Section 301.6224(c)-3T also issued under 26 U.S.C. 6230 (i) and (k). Section 301.6225-1 also issued under 26 U.S.C. 6225. Section 301.6225-2 also issued under 26 U.S.C. 6223 and 6225. Section 301.6225-3 also issued under 26 U.S.C. 6225. Section 301.6226-1 also issued under 26 U.S.C. 6223 and 6226. Section 301.6226-2 also issued under 26 U.S.C. 6226. Section 301.6226-3 also issued under 26 U.S.C. 6226. Section 301.6226(a)-1T also issued under 26 U.S.C. 6230(k). Section 301.6226(b)-1T also issued under 26 U.S.C. 6230(k). Section 301.6226(e)-1T also issued under 26 U.S.C. 6230(k). Section 301.6226(f)-1T also issued under 26 U.S.C. C. 6230(k). Section 301.6227-1 also issued under 26 U.S.C. 6223 and 6227. Section 301.6227-2 also issued under 26 U.S.C. 6227. Section 301.6227-3 also issued under 26 U.S.C. 6227. Section 301.6229(c)(2)-1 is also issued under 26 U.S.C. 6230(k). Section 301.6229(c)(2)-1T also issued under 26 U.S.C. § 6230(k). Section 301.6231-1 also issued under 26 U.S.C. 6231. Section 301.6231(a)(6)-1T also issued under 26 U.S.C. 6230(k). Section 301.6231(a)(7)-1 also issued under 26 U.S.C. 6230 (i) and (k). Section 301.6231(a)(7)-2 also issued under 26 U.S.C. 6230 (i) and (k). Section 301.6231(a)(12)-1T also issued under 26 U.S.C. 6230(k) and 6231(a)(12). Section 301.6231(c)-1 also issued under 26 U.S.C. 6231(c)(1) and (3). Section 301.6231(c)-2 also issued under 26 U.S.C. 6231(c)(1) and (3). Section 301.6231(c)-3T also issued under 26 U.S.C. 6230(k) and 6231(c). Section 301.6231(c)-4T also issued under 26 U.S.C. 6230(k) and 6231(c). Section 301.6231(c)-5T also issued under 26 U.S.C. 6230(k) and 6231(c). Section 301.6231(c)-6T also issued under 26 U.S.C. 6230(k) and 6231(c). Section 301.6231(c)-7T also issued under 26 U.S.C. 6230(k) and 6231(c). Section 301.6231(c)-8T also issued under 26 U.S.C. 6230(k) and 6231(c). Section 301.6231(d)-1T also issued under 26 U.S.C. 6230(k). Section 301.6231(e)-1T also issued under 26 U.S.C. 6230(k). Section 301.6231(e)-2T also issued under 26 U.S.C. 6230(k). Section 301.6231(f)-1T also issued under 26 U.S.C. 6230 (i) and (k) and 6231(f). Section 301.6232-1 also issued under 26 U.S.C. 6232. Section 301.6233-1T also issued under 26 U.S.C. 6230(k) and 6233. Section 301.6233(a)-1 also issued under 26 U.S.C. 6233. Section 301.6233(b)-1 also issued under 26 U.S.C. 6233. Section 301.6234-1 also issued under 26 U.S.C. 6234. Section 301.6235-1 also issued under 26 U.S.C. 6235. Section 301.6241-1 also issued under sections 48D(d), 6241, and 6417. Section 301.6241-2 also issued under 26 U.S.C. 6241. Section 301.6241-3 also issued under 26 U.S.C. 6241. Section 301.6241-4 also issued under 26 U.S.C. 6241. Section 301.6241-5 also issued under 26 U.S.C. 6241. Section 301.6241-6 also issued under 26 U.S.C. 6241. Section 301.6241-7 also issued under sections 48D(d), 6241, and 6417. Section 301.6311-2 also issued under 26 U.S.C. 6311. Section 301.6323(f)-(1)(c) also issued under 26 U.S.C. 6323(f)(3). Section 301.6325-1T also issued under 26 U.S.C. 6326. Section 301.6335-1 also issued under 26 U.S.C. 6335(e)(2). Section 301.6343-1 also issued under 26 U.S.C. 6343. Section 301.6343-2 also issued under 26 U.S.C. 6343. Section 301.6402-2(g) also issued under 26 U.S.C. 6402(n). Section 301.6402-3 also issued under 95 Stat. 357 amending 88 Stat. 2351. Section 301.6402-7 also issued under 26 U.S.C. 6402(i) and 6411(c). Section 301.6404-2 also issued under 26 U.S.C. 6404. Section 301.6404-3 also issued under 26 U.S.C. 6404(f)(3). Section 301.6621-1 also issued under 26 U.S.C. 6230(k). Section 301.6689-1 also issued under 26 U.S.C. 6689(a), 26 U.S.C. 6227(d), and 26 U.S.C. 6241(11). Section 301.6689-1T also issued under 26 U.S.C. 6689(a). Section 301.6708-1 also issued under 26 U.S.C. 6708 Section 301.6721-1 also issued under 26 U.S.C. 6011 and 6721. Section 301.6751(b)-1(a)(4) also issued under 26 U.S.C. 6751(b)(1). Section 301.7216-2, paragraphs (o) and (p) also issued under 26 U.S.C. 7216(b)(3). Section 301.7502-1 also issued under 26 U.S.C. 7502. Section 301.7502-2 also issued under 26 U.S.C. 7502. Section 301.7507-1 also issued under 26 U.S.C. 597. Section 301.7507-9 also issued under 26 U.S.C. 597. Section 301.7508-1 also issued under 26 U.S.C. 7508(a)(1)(K). Section 301.7508A-1 also issued under 26 U.S.C. 7508(a)(1)(K) and 7508A(a). Section 301.7605-1 also issued under section 6228(b) of the Technical and Miscellaneous Revenue Act of 1988. Sections 301.7623-1 through 301.7623-4 also issued under 26 U.S.C. 7623. Section 301.7624-1 also issued under 26 U.S.C. 7624. Section 301.7701-1(a)(4) also issued under 26 U.S.C. 7701(a)(40). Section 301.7701-2 also issued under 26 U.S.C. 7701. Sections 301.7701(b)-1 through 301.7701(b)-9 also issued under 26 U.S.C. 7701(b)(11). Section 301.7701(i)-1(g)(1) also issued under 26 U.S.C. 7701(i)(2)(D). Section 301.7701(i)-4(b) also issued under 26 U.S.C. 7701(i)(3). Section 301.7705-1 also issued under 26 U.S.C. 7705(h). Section 301.7705-2 also issued under 26 U.S.C. 7705(h). Section 301.7803-2 is also issued under 26 U.S.C. 7803(e). Section 301.7803-3 is also issued under 26 U.S.C. 7803(e). Section 301.9000-1 also issued under 5 U.S.C. 301 and 26 U.S.C. 6103(q) and 7804; Section 301.9000-2 also issued under 5 U.S.C. 301 and 26 U.S.C. 6103(q) and 7804; Section 301.9000-3 also issued under 5 U.S.C. 301 and 26 U.S.C. 6103(q) and 7804; Section 301.9000-4 also issued under 5 U.S.C. 301 and 26 U.S.C. 6103(q) and 7804; Section 301.9000-5 also issued under 5 U.S.C. 301 and 26 U.S.C. 6103(q) and 7804; Section 301.9000-6 also issued under 5 U.S.C. 301 and 26 U.S.C. 6103(q) and 7804; Section 301.9100-1T also issued under 26 U.S.C. 6081. Section 301.9100-2T also issued under 26 U.S.C. 6081. Section 301.9100-3T also issued under 26 U.S.C. 6081. Section 301.9100-4T also issued under 26 U.S.C. 168(f)(8)(G). Section 301.9100-7T also issued under 26 U.S.C. 42, 48, 56, 83, 141, 142, 143, 145, 147, 165, 168, 216, 263, 263A, 448, 453C, 468B, 469, 474, 585, 616, 617, 1059, 2632, 2652, 3121, 4982, 7701; and under the Tax Reform Act of 1986, 100 Stat. 2746, sections 203, 204, 243, 311, 646, 801, 806, 905, 1704, 1801, 1802, and 1804. Section 301.9100-8 also issued under 26 U.S.C. 1(i)(7), 41(h), 42(b)(2)(A)(ii), 42(d)(3), 42(f)(1), 42(g)(3), 42(i)(2)(B), 42(j)(5)(B), 121(d)(9), 142(i)(2), 165(l), 168(b)(2), 219(g)(4), 245(a)(10), 263A(d)(1), 263A(d)(3)(B), 263A(h), 460(b)(3), 643(g)(2), 831(b)(2)(A), 835(a), 865(f), 865(g)(3), 865(h)(2), 904(g)(10), 2056(b)(7)(c)(ii), 2056A(d), 2523(f)(6)(B), 3127, and 7520(a); the Technical and Miscellaneous Revenue Act of 1988, 102 Stat. 3324, sections 1002(a)(23)(B), 1005(c)(11), 1006(d)(15), 1006(j)(1)(C), 1006(t)(18)(B), 1012(n)(3), 1014(c)(1), 1014(c)(2), 2004(j)(1), 2004(m)(5), 5012(e)(4), 6181(c)(2), and 6277; and under the Tax Reform Act of 1986, 100 Stat. 2746, section 905(a). Sections 301.9100-9T, 301.9100-10T and 301.9100-11T also issued under 26 U.S.C. 1103 (g) and (h) and 6158(a). Sections 301.9100-13T, 301.9100-14T and 301.9100-15T also issued under 26 U.S.C. 108(d)(8) and 1017(b)(3)(E). Section 301.9100-16T also issued under 26 U.S.C. 463(d). Section 301.9100-22T is also issued under section 1101(g)(4) of Public Law 114-74.
Source
Source: 32 FR 15241, Nov. 3, 1967, unless otherwise noted.
Amendments
[T.D. 7305, 39 FR 9950, Mar. 15, 1974]