Internal Revenue Code · 26 U.S.C.
§ 6320. Notice and opportunity for hearing upon filing of notice of lien
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. § 6320
At a glance
Read from the text, the source credit and the official notes. Not part of the law.
- Status
- In force
- Added
- July 22, 1998 by Pub. L. 105–206
- Last amended
- July 1, 2019 by Pub. L. 116–25
- Amendments
- 4 dated changes in the source credit
- Length
- 3 subsections · 454 words · about 2 min to read
- Cross-references
- cites 3; cited by 6 Code sections and 4 other regulations
- Regulations
- 1 issued under this section
The Secretary shall notify in writing the person described in section 6321 of the filing of a notice of lien under section 6323.
The hearing under this subsection shall be conducted by an officer or employee who has had no prior involvement with respect to the unpaid tax specified in subsection (a)(3)(A) before the first hearing under this section or section 6330. A taxpayer may waive the requirement of this paragraph.
To the extent practicable, a hearing under this section shall be held in conjunction with a hearing under section 6330.
For purposes of this section, subsections (c), (d) (other than paragraph (3)(B) thereof), (e), and (g) of section 6330 shall apply.
(Added Pub. L. 105–206, title III, § 3401(a), July 22, 1998, 112 Stat. 746; amended Pub. L. 109–432, div. A, title IV, § 407(c), Dec. 20, 2006, 120 Stat. 2962; Pub. L. 114–94, div. C, title XXXII, § 32101(b)(1), Dec. 4, 2015, 129 Stat. 1731; Pub. L. 114–113, div. Q, title IV, § 424(c), Dec. 18, 2015, 129 Stat. 3125; Pub. L. 116–25, title I, § 1001(b)(1)(B), July 1, 2019, 133 Stat. 985.)
Regulations under this section
Treasury regulations (26 CFR) issued under § 6320
From Carry Forward Learning, not part of the law
Our pages that use this section
IRS notice guide
Cross-references
Computed from the citations in the text of Title 26 and 26 CFR.
This section cites 3 other sections
- § 6323 Validity and priority against certain persons
- § 7345 Revocation or denial of passport in case of certain tax delinquencies
- § 6330 Notice and opportunity for hearing before levy
Cited by 6 Code sections
- § 6330(b)(3) Notice and opportunity for hearing before levy
- § 6702(b)(2)(B)(i)(I) Frivolous tax submissions
- § 7345(b)(1)(C)(i) Revocation or denial of passport in case of certain tax delinquencies
- § 7443A(b)(4) Special trial judges
- § 7482(b)(1)(G) Courts of review
- § 7803(d)(1)(A)(iii) Commissioner of Internal Revenue; other officials
Cited in 4 regulations not issued under it
- § 1.6015-5 Time and manner for requesting relief.
- § 301.6330-1 Notice and opportunity for hearing prior to levy.
- § 301.7430-3 Administrative proceeding and administrative proceeding date.
- § 301.7803-2 Internal Revenue Service Independent Office of Appeals resolution of Federal tax controversies without litigation.
Amendment history
From the source credit and the official notes, newest first.
Where it sits in the Code
Official notes
Show the Law Revision Counsel's notes (amendments, effective dates)
Editorial Notes
References in Text
Section 32101 of the FAST Act, referred to in subsec. (a)(3)(E), is section 32101 of Pub. L. 114–94, which enacted section 7345 of this title and section 2714a of Title 22, Foreign Relations and Intercourse, and amended this section and sections 6103, 6331, and 7508 of this title.
Amendments
2019—Subsec. (b)(1). Pub. L. 116–25 substituted “Internal Revenue Service Independent Office of Appeals” for “Internal Revenue Service Office of Appeals”.
2015—Subsec. (a)(3)(E). Pub. L. 114–94 added subpar. (E).
Subsec. (c). Pub. L. 114–113 substituted “(3)(B)” for “(2)(B)”.
2006—Subsec. (b)(1). Pub. L. 109–432, § 407(c)(1), substituted “in writing under subsection (a)(3)(B) and states the grounds for the requested hearing” for “under subsection (a)(3)(B)”.
Subsec. (c). Pub. L. 109–432, § 407(c)(2), substituted “(e), and (g)” for “and (e)”.
Statutory Notes and Related Subsidiaries
Effective Date of 2006 Amendment
Pub. L. 109–432, div. A, title IV, § 407(f), Dec. 20, 2006, 120 Stat. 2962, provided that: “The amendments made by this section [amending this section and sections 6330, 6702, and 7122 of this title] shall apply to submissions made and issues raised after the date on which the Secretary first prescribes a list under section 6702(c) of the Internal Revenue Code of 1986, as amended by subsection (a) [list prescribed Mar. 16, 2007, see I.R.S. Notice 2007–30, 2007–14, I.R.B. 883].”
Effective Date
Pub. L. 105–206, title III, § 3401(d), July 22, 1998, 112 Stat. 750, provided that: “The amendments made by this section [enacting this section and section 6330 of this title and amending section 7443A of this title] shall apply to collection actions initiated after the date which is 180 days after the date of the enactment of this Act [July 22, 1998].”