---
kind: "section"
citation: "26 U.S.C. § 6406"
title: "26"
title_heading: "Internal Revenue Code"
number: "6406"
heading: "Prohibition of administrative review of decisions"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/6406"
units:
  - "Subtitle F — Procedure and Administration"
  - "Chapter 65 — Abatements, Credits, and Refunds"
  - "Subchapter A — Procedure in General"
---

# §6406. Prohibition of administrative review of decisions


In the absence of fraud or mistake in mathematical calculation, the findings of fact in and the decision of the [Secretary](/usc/26/7701.md?p=a-11-B) upon the merits of any claim presented under or authorized by the internal revenue laws and the allowance or non-allowance by the [Secretary](/usc/26/7701.md?p=a-11-B) of interest on any credit or refund under the internal revenue laws shall not, except as provided in subchapters C and D of [chapter 76](/usc/26/chstF/ch76.md) (relating to the [Tax Court](/usc/26/7701.md?p=a-27)), be subject to review by any other administrative or accounting officer, [employee](/usc/26/7701.md?p=a-20), or agent of the [United States](/usc/26/7701.md?p=a-9).


## Source credit

(Aug. 16, 1954, ch. 736, 68A Stat. 792; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)

## Notes

### Editorial Notes

### Amendments

1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary” wherever appearing.