---
kind: "section"
citation: "26 U.S.C. § 7458"
title: "26"
title_heading: "Internal Revenue Code"
number: "7458"
heading: "Hearings"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/7458"
units:
  - "Subtitle F — Procedure and Administration"
  - "Chapter 76 — Judicial Proceedings"
  - "Subchapter C — The Tax Court"
  - "Part II — Procedure"
---

# §7458. Hearings


Notice and opportunity to be heard upon any proceeding instituted before the [Tax Court](/usc/26/7701.md?p=a-27) shall be given to the [taxpayer](/usc/26/7701.md?p=a-14) and the [Secretary](/usc/26/7701.md?p=a-11-B). If an opportunity to be heard upon the proceeding is given before a division of the [Tax Court](/usc/26/7701.md?p=a-27), neither the [taxpayer](/usc/26/7701.md?p=a-14) nor the [Secretary](/usc/26/7701.md?p=a-11-B) shall be entitled to notice and opportunity to be heard before the [Tax Court](/usc/26/7701.md?p=a-27) upon review, except upon a specific order of the chief judge. Hearings before the [Tax Court](/usc/26/7701.md?p=a-27) and its divisions shall be open to the public, and the testimony, and, if the [Tax Court](/usc/26/7701.md?p=a-27) so requires, the argument, shall be stenographically reported. The [Tax Court](/usc/26/7701.md?p=a-27) is authorized to [contract](/usc/26/101.md?p=f-3-A) (by renewal of [contract](/usc/26/101.md?p=f-3-A) or otherwise) for the reporting of such hearings, and in such [contract](/usc/26/101.md?p=f-3-A) to fix the terms and conditions under which transcripts will be supplied by the contractor to the [Tax Court](/usc/26/7701.md?p=a-27) and to other [persons](/usc/26/7701.md?p=a-1) and agencies.


## Source credit

(Aug. 16, 1954, ch. 736, 68A Stat. 886; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), (L), Oct. 4, 1976, 90 Stat. 1834, 1835.)

## Notes

### Editorial Notes

### Amendments

1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary” and struck out “nor his delegate” after “nor the Secretary”.