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Internal Revenue Code · 26 U.S.C.

§ 6215. Assessment of deficiency found by Tax Court

In force Text current through Public Law 119-121 (October 9, 2026) release point 119-121

Official text, no changes From the Office of the Law Revision Counsel, release point 119-121 (current through Public Law 119-121 (October 9, 2026)). Compare it with the official text at uscode.house.gov (external site).

Cite as 26 U.S.C. § 6215

At a glance

Read from the text, the source credit and the official notes. Not part of the law.

Status
In force
Enacted
October 4, 1976 by Pub. L. 94–455
Last amended
March 23, 2018 by Pub. L. 115–141
Amendments
2 dated changes in the source credit
Length
2 subsections · 258 words · about 1 min to read
Cross-references
cites 4; cited by 2 Code sections and 1 other regulation
Regulations
1 issued under this section
(a) General rule

If the taxpayer files a petition with the Tax Court, the entire amount redetermined as the deficiency by the decision of the Tax Court which has become final shall be assessed and shall be paid upon notice and demand from the Secretary. No part of the amount determined as a deficiency by the Secretary but disallowed as such by the decision of the Tax Court which has become final shall be assessed or be collected by levy or by proceeding in court with or without assessment.

(b) Cross references
(1) For assessment or collection of the amount of the deficiency determined by the Tax Court pending appellate court review, see section 7485.
(2) For dismissal of petition by Tax Court as affirmation of deficiency as determined by the Secretary, see section 7459(d).
(3) For decision of Tax Court that tax is barred by limitation as its decision that there is no deficiency, see section 7459(e).
(4) For assessment of damages awarded by Tax Court for instituting proceedings merely for delay, see section 6673.
(5) For rules applicable to Tax Court proceedings, see generally subchapter C of chapter 76.
(6) For extension of time for paying amount determined as deficiency, see section 6161(b).

(Aug. 16, 1954, ch. 736, 68A Stat. 773; Pub. L. 94–455, title XIX, § 1906(a)(16), (b)(13)(A), Oct. 4, 1976, 90 Stat. 1825, 1834; Pub. L. 99–514, title XIV, § 1404(c)(2), Oct. 22, 1986, 100 Stat. 2714; Pub. L. 115–141, div. U, title IV, § 401(b)(46), Mar. 23, 2018, 132 Stat. 1204.)

Regulations under this section

Treasury regulations (26 CFR) issued under § 6215

Cross-references

Computed from the citations in the text of Title 26 and 26 CFR.

This section cites 4 other sections

Cited by 2 Code sections

Cited in 1 regulation not issued under it

Amendment history

From the source credit and the official notes, newest first.

  1. Amended by Pub. L. 115–141Parts changed in 2018: (b)(5)
  2. Amended by Pub. L. 99–514Parts changed in 1986: (b)(7)
  3. Enacted by Pub. L. 94–455Parts changed in 1976: (b)(5)

Where it sits in the Code

  1. Subtitle F Procedure and Administration
  2. Chapter 63 ASSESSMENT
  3. Subchapter B Deficiency Procedures in the Case of Income, Estate, Gift, and Certain Excise Taxes

Nearby sections

Official notes

Show the Law Revision Counsel's notes (amendments, effective dates)

Editorial Notes

Amendments

2018—Subsec. (b)(5) to (7). Pub. L. 115–141 redesignated pars. (6) and (7) as (5) and (6), respectively, and struck out former par. (5) which read as follows: “For treatment of certain deficiencies as having been paid, in connection with sale of surplus war-built vessels, see section 9(b)(8) of the Merchant Ship Sales Act of 1946 (50 U.S.C. App. 1742).”

1986—Subsec. (b)(7), (8). Pub. L. 99–514 redesignated par. (8) as (7) and struck out former par. (7) which read as follows: “For proration of deficiency to installments, see section 6152(c).”

1976—Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary” wherever appearing.

Subsec. (b)(5). Pub. L. 94–455, § 1906(a)(16), struck out “60 Stat. 48;” before “50 U.S.C. App. 1742”.

Statutory Notes and Related Subsidiaries

Effective Date of 1986 Amendment

Amendment by Pub. L. 99–514 applicable to taxable years beginning after Dec. 31, 1986, see section 1404(d) of Pub. L. 99–514, set out as a note under section 643 of this title.

Savings Provision

For provisions that nothing in amendment by Pub. L. 115–141 be construed to affect treatment of certain transactions occurring, property acquired, or items of income, loss, deduction, or credit taken into account prior to Mar. 23, 2018, for purposes of determining liability for tax for periods ending after Mar. 23, 2018, see section 401(e) of Pub. L. 115–141, set out as a note under section 23 of this title.