---
kind: "section"
citation: "26 U.S.C. § 6326"
title: "26"
title_heading: "Internal Revenue Code"
number: "6326"
heading: "Administrative appeal of liens"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/6326"
units:
  - "Subtitle F — Procedure and Administration"
  - "Chapter 64 — Collection"
  - "Subchapter C — Lien for Taxes"
  - "Part II — Liens"
---

# §6326. Administrative appeal of liens

- (a) **In general—** In such form and at such time as the [Secretary](/usc/26/7701.md?p=a-11-B) shall prescribe by regulations, any [person](/usc/26/7701.md?p=a-1) shall be allowed to appeal to the [Secretary](/usc/26/7701.md?p=a-11-B) after the filing of a notice of a lien under this subchapter on the property or the rights to property of such [person](/usc/26/7701.md?p=a-1) 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](/usc/26/7701.md?p=a-11-B) determines that the filing of the notice of any lien was erroneous, the [Secretary](/usc/26/7701.md?p=a-11-B) 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.)

## Notes

### Editorial Notes

### Prior Provisions

A prior section 6326 was renumbered 6327 of this title.

### Statutory Notes and Related Subsidiaries

### Effective Date

Pub. L. 100–647, title VI, § 6238(d), Nov. 10, 1988, 102 Stat. 3743, provided that: “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].”

### Regulations

Pub. L. 100–647, title VI, § 6238(b), Nov. 10, 1988, 102 Stat. 3743, 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 Nov. 10, 1988.