§ 6330. Notice and opportunity for hearing before levy

Legislative history

Reconstructed from this section’s Code source credit and amendment notes, resolved against the local Statutes at Large. Editorial notes are evidence, not the law that made the change.

1. 1998

   Taxpayer Bill of Rights 3

   Pub. L. 105–206 title III § 3401(b) · 112 Stat. 685

   Enacted · 26 U.S.C. § 6330

   Added Pub. L. 105–206, title III, § 3401(b), July 22, 1998, 112 Stat. 747

   Source evidence

   Code source credit
   Added Pub. L. 105–206, title III, § 3401(b), July 22, 1998, 112 Stat. 747

   Enacted provision · exact public law section
   (b) Notice and Opportunity for Hearing Before Levy.— Subchapter D of chapter 64 (relating to seizure of property for collection of taxes) is amended by inserting before the table of sections the following: “Part I. Due process for collections. “Part II. Levy. “PART I— DUE PROCESS FOR COLLECTIONS “Sec. 6330. Notice and opportunity for hearing before levy. “SEC. 6330. NOTICE AND OPPORTUNITY FOR HEARING BEFORE LEVY. “(a) Requirement of Notice Before Levy.— “(1) In general.— No levy may be made on any property or right to property of any person unless the Secretary has notified such person in writing of their right to a hearing under this section before such levy is made. Such notice shall be required only once for the taxable period to which the unpaid tax specified in paragraph (3)(A) relates. “(2) Time and method for notice.— The notice required under paragraph (1) shall be— “(A) given in person; “(B) left at the dwelling or usual place of business of such person; or “(C) sent by certified or registered mail, return receipt requested, to such person’s last known address; not less than 30 days before the day of the first levy with respect to the amount of the unpaid tax for the taxable period. “(3) Information included with notice.— The notice required under paragraph (1) shall include in simple and nontechnical terms— “(A) the amount of unpaid tax; “(B) the right of the person to request a hearing during the 30-day period under paragraph (2); and “(C) the proposed action by the Secretary and the rights of the person with respect to such action, including a brief statement which sets forth— “(i) the provisions of this title relating to levy and sale of property; “(ii) the procedures applicable to the levy and sale of property under this title; “(iii) the administrative appeals available to the taxpayer with respect to such levy and sale and the procedures relating to such appeals; “(iv) the alternatives available to taxpayers which could prevent levy on property (including installment agreements under section 6159); and “(v) the provisions of this title and procedures relating to redemption of property and release of liens on property. “(b) Right to Fair Hearing.— “(1) In general.— If the person requests a hearing under subsection (a)(3)(B), such hearing shall be held by the Internal Revenue Service Office of Appeals. “(2) One hearing per period.— A person shall be entitled to only one hearing under this section with respect to the taxable period to which the unpaid tax specified in subsection (a)(3)(A) relates. “(3) Impartial officer.— 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 6320. A taxpayer may waive the requirement of this paragraph. “(c) Matters Considered at Hearing.— In the case of any hearing conducted under this section— “(1) Requirement of investigation.— The appeals officer shall at the hearing obtain verification from the Secretary that the requirements of any applicable law or administrative procedure have been met. “(2) Issues at hearing.— “(A) In general.— The person may raise at the hearing any relevant issue relating to the unpaid tax or the proposed levy, including— “(i) appropriate spousal defenses; “(ii) challenges to the appropriateness of collection actions; and “(iii) offers of collection alternatives, which may include the posting of a bond, the substitution of other assets, an installment agreement, or an offer-in-copromise. “(B) Underlying liability.— The person may also raise at the hearing challenges to the existence or amount of the underlying tax liability for any tax period if the person did not receive any statutory notice of deficiency for such tax liability or did not otherwise have an opportunity to dispute such tax liability. “(3) Basis for the determination.— The determination by an appeals officer under this subsection shall take into consideration— “(A) the verification presented under paragraph (1); “(B) the issues raised under paragraph (2); and “(C) whether any proposed collection action balances the need for the efficient collection of taxes with the legitimate concern of the person that any collection action be no more intrusive than necessary. “(4) Certain issues precluded.— An issue may not be raised at the hearing if— “(A) the issue was raised and considered at a previous hearing under section 6320 or in any other previous administrative or judicial proceeding; and “(B) the person seeking to raise the issue participated meaningfully in such hearing or proceeding. This paragraph shall not apply to any issue with respect to which subsection (d)(2)(B) applies. “(d) Proceeding After Hearing.— “(1) Judicial review of determination.— The person may, within 30 days of a determination under this section, appeal such determination— “(A) to the Tax Court (and the Tax Court shall have jurisdiction to hear such matter); or “(B) if the Tax Court does not have jurisdiction of the underlying tax liability, to a district court of the United States. If a court determines that the appeal was to an incorrect court, a person shall have 30 days after the court determination to file such appeal with the correct court. “(2) Jurisdiction retained at irs office of appeals.— The Internal Revenue Service Office of Appeals shall retain jurisdiction with respect to any determination made under this section, including subsequent hearings requested by the person who requested the original hearing on issues regarding— “(A) collection actions taken or proposed with respect to such determination; and “(B) after the person has exhausted all administrative remedies, a change in circumstances with respect to such person which affects such determination. “(e) Suspension of Collections and Statute of Limitations.— “(1) In general.— Except as provided in paragraph (2), if a hearing is requested under subsection (a)(3)(B), the levy actions which are the subject of the requested hearing and the running of any period of limitations under section 6502 (relating to collection after assessment), section 6531 (relating to criminal prosecutions), or section 6532 (relating to other suits) shall be suspended for the period during which such hearing, and appeals therein, are pending. In no event shall any such period expire before the 90th day after the day on which there is a final determination in such hearing. “(2) Levy upon appeal.— Paragraph (1) shall not apply to a levy action while an appeal is pending if the underlying tax liability is not at issue in the appeal and the court determines that the Secretary has shown good cause not to suspend the levy. “(f) Jeopardy and State Refund Collection.— If— “(1) the Secretary has made a finding under the last sentence of section 6331(a) that the collection of tax is in jeopardy; or “(2) the Secretary has served a levy on a State to collect a Federal tax liability from a State tax refund, this section shall not apply, except that the taxpayer shall be given the opportunity for the hearing described in this section within a reasonable period of time after the levy. “PART II— LEVY”.

2. 2000

   Consolidated Appropriations Act, 2001

   Pub. L. 106–554 § 1(a)(7)(tIII)(s313)(d) · 114 Stat. 2763

   Substituted · 26 U.S.C. § 6330(d)(1)(A)

   Pub. L. 106–554, § 1(a)(7) [title III, § 313(d)], substituted “with respect to” for “to hear”

   Source evidence

   Code amendment note
   Subsec. (d)(1)(A). Pub. L. 106–554, § 1(a)(7) [title III, § 313(d)], substituted “with respect to” for “to hear”.

   Enacted provision · exact public law section
   (7) H.R. 5662, as introduced on December 14, 2000.

3. 2000

   Consolidated Appropriations Act, 2001

   Pub. L. 106–554 § 1(a)(7)(tIII)(s313)(b)(2)(A) · 114 Stat. 2763

   Inserted · 26 U.S.C. § 6330(e)(1)

   Pub. L. 106–554, § 1(a)(7) [title III, § 313(b)(2)(A)], inserted at end “Notwithstanding the provisions of section 7421(a), the beginning of a levy or proceeding during the time the suspension under this paragraph is in force may be enjoined by a proceeding in the proper court, including the Tax Court. The Tax Court shall have no jurisdiction under this paragraph to enjoin any action or proceeding unless a timely appeal has been filed under subsection (d)(1) and then only in respect of the unpaid tax or proposed levy to which the determination being appealed relates.”

   Source evidence

   Code amendment note
   Subsec. (e)(1). Pub. L. 106–554, § 1(a)(7) [title III, § 313(b)(2)(A)], inserted at end “Notwithstanding the provisions of section 7421(a), the beginning of a levy or proceeding during the time the suspension under this paragraph is in force may be enjoined by a proceeding in the proper court, including the Tax Court. The Tax Court shall have no jurisdiction under this paragraph to enjoin any action or proceeding unless a timely appeal has been filed under subsection (d)(1) and then only in respect of the unpaid tax or proposed levy to which the determination being appealed relates.”

   Enacted provision · exact public law section
   (7) H.R. 5662, as introduced on December 14, 2000.

4. 2006

   Pub. L. 109–280 § 855(a) · 120 Stat. 780

   Amended · 26 U.S.C. § 6330(d)(1)

   Pub. L. 109–280, § 855(a), reenacted heading without change and amended text of par. (1) generally. Prior to amendment, text read as follows: “The person may, within 30 days of a determination under this section, appeal such determination—

   Source evidence

   Code amendment note
   Subsec. (d)(1). Pub. L. 109–280, § 855(a), reenacted heading without change and amended text of par. (1) generally. Prior to amendment, text read as follows: “The person may, within 30 days of a determination under this section, appeal such determination—

   “(A) to the Tax Court (and the Tax Court shall have jurisdiction with respect to such matter); or “(B) if the Tax Court does not have jurisdiction of the underlying tax liability, to a district court of the United States. If a court determines that the appeal was to an incorrect court, a person shall have 30 days after the court determination to file such appeal with the correct court.”

   Enacted provision · exact public law section
   (a) In General.— Paragraph (1) of section 6330(d) of the Internal Revenue Code of 1986 (relating to proceeding after hearing) is amended to read as follows: “(1) Judicial review of determination.— The Deadline. person may, within 30 days of a determination under this section, appeal such determination to the Tax Court (and the Tax Court shall have jurisdiction with respect to such matter).” .

5. 2006

   Tax Relief and Health Care Act of 2006

   Pub. L. 109–432 § 407(b)(3) · 120 Stat. 2922

   Substituted · 26 U.S.C. § 6330(b)(1)

   Pub. L. 109–432, § 407(b)(3), substituted “in writing under subsection (a)(3)(B) and states the grounds for the requested hearing” for “under subsection (a)(3)(B)”

   Source evidence

   Code amendment note
   Subsec. (b)(1). Pub. L. 109–432, § 407(b)(3), substituted “in writing under subsection (a)(3)(B) and states the grounds for the requested hearing” for “under subsection (a)(3)(B)”.

   Enacted provision · exact public law section
   (3) Statement of grounds.— Section 6330(b)(1) is amended by striking “under subsection (a)(3)(B)” and inserting “in writing under subsection (a)(3)(B) and states the grounds for the requested hearing”.

6. 2006

   Tax Relief and Health Care Act of 2006

   Pub. L. 109–432 § 407(b)(2) · 120 Stat. 2922

   1. Redesignated · 26 U.S.C. § 6330(c)(4)(A); 26 U.S.C. § 6330(c)(4)(B)

      Pub. L. 109–432, § 407(b)(2), redesignated subpars. (A) and (B) as cls. (i) and (ii), respectively, of subpar. (A), in cl. (ii) substituted “; or” for period at end

   2. Added · 26 U.S.C. § 6330(c)(4)(A); 26 U.S.C. § 6330(c)(4)(B)

      Pub. L. 109–432, § 407(b)(2), added subpar. (B)

   Source evidence

   Code amendment note
   Subsec. (c)(4)(A), (B). Pub. L. 109–432, § 407(b)(2), redesignated subpars. (A) and (B) as cls. (i) and (ii), respectively, of subpar. (A), in cl. (ii) substituted “; or” for period at end, and added subpar. (B).

   Enacted provision · exact public law section
   (2) Preclusion from raising frivolous issues at hearing.— Section 6330(c)(4) is amended— (A) by striking “(A)” and inserting “(A)(i)”; (B) by striking “(B)” and inserting “(ii)”; (C) by striking the period at the end of the first sentence and inserting “; or”; and (D) by inserting after subparagraph (A)(ii) (as so redesignated) the following: “(B) the issue meets the requirement of clause (i) or (ii) of section 6702(b)(2)(A).” .

7. 2006

   Tax Relief and Health Care Act of 2006

   Pub. L. 109–432 § 407(b)(1) · 120 Stat. 2922

   Added · 26 U.S.C. § 6330(g)

   Pub. L. 109–432, § 407(b)(1), added subsec. (g)

   Source evidence

   Code amendment note
   Subsec. (g). Pub. L. 109–432, § 407(b)(1), added subsec. (g).

   Enacted provision · exact public law section
   (1) Frivolous requests disregarded.— Section 6330 (relating to notice and opportunity for hearing before levy) is amended by adding at the end the following new subsection: “(g) Frivolous Requests for Hearing, etc.— Notwithstanding any other provision of this section, if the Secretary determines that any portion of a request for a hearing under this section or section 6320 meets the requirement of clause (i) or (ii) of section 6702(b)(2)(A), then the Secretary may treat such portion as if it were never submitted and such portion shall not be subject to any further administrative or judicial review.” .

8. 2007

   Small Business and Work Opportunity Tax Act of 2007

   Pub. L. 110–28 § 8243(a) · 121 Stat. 112

   Added · 26 U.S.C. § 6330(f)(3)

   Pub. L. 110–28, § 8243(a), added par. (3)

   Source evidence

   Code amendment note
   Subsec. (f)(3). Pub. L. 110–28, § 8243(a), added par. (3).

   Enacted provision · exact public law section
   (a) In General.— Section 6330(f) (relating to jeopardy and State refund collection) is amended— (1) by striking “; or” at the end of paragraph (1) and inserting a comma, (2) by adding “or” at the end of paragraph (2), and (3) by inserting after paragraph (2) the following new paragraph: “(3) the Secretary has served a disqualified employment tax levy,” .

9. 2007

   Small Business and Work Opportunity Tax Act of 2007

   Pub. L. 110–28 § 8243(b) · 121 Stat. 112

   Added · 26 U.S.C. § 6330(h)

   Pub. L. 110–28, § 8243(b), added subsec. (h)

   Source evidence

   Code amendment note
   Subsec. (h). Pub. L. 110–28, § 8243(b), added subsec. (h).

   Enacted provision · exact public law section
   (b) Disqualified Employment Tax Levy.— Section 6330 of such Code (relating to notice and opportunity for hearing before levy) is amended by adding at the end the following new subsection: “(h) Disqualified Employment Tax Levy.— For purposes of subsection (f), a disqualified employment tax levy is any levy in connection with the collection of employment taxes for any taxable period if the person subject to the levy (or any predecessor thereof) requested a hearing under this section with respect to unpaid employment taxes arising in the most recent 2-year period before the beginning of the taxable period with respect to which the levy is served. For purposes of the preceding sentence, the term ‘employment taxes’ means any taxes under chapter 21, 22, 23, or 24.” .

10. 2010

    Creating Small Business Jobs Act of 2010

    Pub. L. 111–240 § 2104(c) · 124 Stat. 2504

    Substituted · 26 U.S.C. § 6330(f)

    Pub. L. 111–240, § 2104(c), substituted “Exceptions” for “Jeopardy and State refund collection” in heading

    Source evidence

    Code amendment note
    Subsec. (f). Pub. L. 111–240, § 2104(c), substituted “Exceptions” for “Jeopardy and State refund collection” in heading.

    Enacted provision · exact public law section
    (c) Conforming Amendment.— The heading of subsection (f) of section 6330 of the Internal Revenue Code of 1986 is amended by striking “Jeopardy and State Refund Collection” and inserting “Exceptions”.

11. 2010

    Creating Small Business Jobs Act of 2010

    Pub. L. 111–240 § 2104(a) · 124 Stat. 2504

    Added · 26 U.S.C. § 6330(f)(4)

    Pub. L. 111–240, § 2104(a), added par. (4)

    Source evidence

    Code amendment note
    Subsec. (f)(4). Pub. L. 111–240, § 2104(a), added par. (4).

    Enacted provision · exact public law section
    (a) In General.— Subsection (f) of section 6330 of the Internal Revenue Code of 1986 26 USC 6330. is amended by striking “or” at the end of paragraph (2), by inserting “or” at the end of paragraph (3), and by inserting after paragraph (3) the following new paragraph: “(4) the Secretary has served a Federal contractor levy,” .

12. 2010

    Creating Small Business Jobs Act of 2010

    Pub. L. 111–240 § 2104(b) · 124 Stat. 2504

    1. Substituted · 26 U.S.C. § 6330(h)

       Pub. L. 111–240, § 2104(b), substituted “Definitions related to exceptions” for “Disqualified employment tax levy” in heading

    2. Inserted · 26 U.S.C. § 6330(h)

       Pub. L. 111–240, § 2104(b), inserted introductory provisions and par. (1) designation and heading

    3. Substituted · 26 U.S.C. § 6330(h)

       Pub. L. 111–240, § 2104(b), substituted “A disqualified employment tax levy is” for “For purposes of subsection (f), a disqualified employment tax levy is”

    4. Added · 26 U.S.C. § 6330(h)

       Pub. L. 111–240, § 2104(b), added par. (2)

    Source evidence

    Code amendment note
    Subsec. (h). Pub. L. 111–240, § 2104(b), substituted “Definitions related to exceptions” for “Disqualified employment tax levy” in heading, inserted introductory provisions and par. (1) designation and heading, substituted “A disqualified employment tax levy is” for “For purposes of subsection (f), a disqualified employment tax levy is”, and added par. (2).

    Enacted provision · exact public law section
    (b) Federal Contractor Levy.— Subsection (h) of section 6330 of the Internal Revenue Code of 1986 is amended— (1) by striking all that precedes “any levy in connection with the collection” and inserting the following: “(h) Definitions Related to Exceptions.— For purposes of subsection (f)— “(1) Disqualified employment tax levy.— A disqualified employment tax levy is” ; and (2) by adding at the end the following new paragraph: “(2) Federal contractor levy.— A Federal contractor levy is any levy if the person whose property is subject to the levy (or any predecessor thereof) is a Federal contractor.” .

13. 2015

    <Bipartisan Budget Act of 2015>

    Pub. L. 114–74 title XI § 1101(d) · 129 Stat. 584

    Added · 26 U.S.C. § 6330(c)(4)(C)

    Pub. L. 114–74 added subpar. (C)

    Source evidence

    Code amendment note
    Subsec. (c)(4)(C). Pub. L. 114–74 added subpar. (C).

    Enacted provision · exact public law section
    (d) Binding Nature of Partnership Adjustment Proceedings.— Section 6330(c)(4) of such Code 26 USC 6330. is amended by striking “or” at the end of subparagraph (A), by striking the period at the end of subparagraph (B) and inserting “; or”, and by inserting after subparagraph (B) the following new subparagraph: “(C) a final determination has been made with respect to such issue in a proceeding brought under subchapter C of chapter 63.” .

    Effective date note
    Pub. L. 114–113, div. Q, title IV, § 424(b)(2), Dec. 18, 2015, 129 Stat. 3124, provided that: “The amendments made by this subsection [amending this section] shall apply to petitions filed under section 6330 of the Internal Revenue Code of 1986 after the date of the enactment of this Act [Dec. 18, 2015].” Amendment by Pub. L. 114–74 applicable to returns filed for partnership taxable years beginning after Dec. 31, 2017, with certain exceptions, see section 1101(g) of Pub. L. 114–74, set out as an Effective Date note under section 6221 of this title.

14. 2015

    Department of the Interior, Environment, and Related Agencies Appropriations Act, 2016

    Pub. L. 114–113 § 424(b)(1)(A) · 129 Stat. 2242

    1. Substituted · 26 U.S.C. § 6330(d)(1)

       Pub. L. 114–113, § 424(b)(1)(A), (B), substituted “Petition for review by Tax Court” for “Judicial review of determination” in text

    2. Substituted · 26 U.S.C. § 6330(d)(1)

       Pub. L. 114–113, § 424(b)(1)(A), (B), substituted “petition the Tax Court for review of such determination” for “appeal such determination to the Tax Court” in text

    Source evidence

    Code amendment note
    Subsec. (d)(1). Pub. L. 114–113, § 424(b)(1)(A), (B), substituted “Petition for review by Tax Court” for “Judicial review of determination” in heading and “petition the Tax Court for review of such determination” for “appeal such determination to the Tax Court” in text.

    Enacted provision · exact public law section
    (1) applying subsection (a) would be inconsistent with the public interest;

    Effective date note
    Pub. L. 114–113, div. Q, title IV, § 424(b)(2), Dec. 18, 2015, 129 Stat. 3124, provided that: “The amendments made by this subsection [amending this section] shall apply to petitions filed under section 6330 of the Internal Revenue Code of 1986 after the date of the enactment of this Act [Dec. 18, 2015].” Amendment by Pub. L. 114–74 applicable to returns filed for partnership taxable years beginning after Dec. 31, 2017, with certain exceptions, see section 1101(g) of Pub. L. 114–74, set out as an Effective Date note under section 6221 of this title.

15. 2015

    Department of the Interior, Environment, and Related Agencies Appropriations Act, 2016

    Pub. L. 114–113 § 424(b)(1)(C) · 129 Stat. 2242

    1. Added · 26 U.S.C. § 6330(d)(2); 26 U.S.C. § 6330(d)(3)

       Pub. L. 114–113, § 424(b)(1)(C), (D), added par. (2)

    2. Redesignated · 26 U.S.C. § 6330(d)(2); 26 U.S.C. § 6330(d)(3)

       Pub. L. 114–113, § 424(b)(1)(C), (D), redesignated former par. (2) as (3)

    Source evidence

    Code amendment note
    Subsec. (d)(2), (3). Pub. L. 114–113, § 424(b)(1)(C), (D), added par. (2) and redesignated former par. (2) as (3).

    Enacted provision · exact public law section
    (1) applying subsection (a) would be inconsistent with the public interest;

    Effective date note
    Pub. L. 114–113, div. Q, title IV, § 424(b)(2), Dec. 18, 2015, 129 Stat. 3124, provided that: “The amendments made by this subsection [amending this section] shall apply to petitions filed under section 6330 of the Internal Revenue Code of 1986 after the date of the enactment of this Act [Dec. 18, 2015].” Amendment by Pub. L. 114–74 applicable to returns filed for partnership taxable years beginning after Dec. 31, 2017, with certain exceptions, see section 1101(g) of Pub. L. 114–74, set out as an Effective Date note under section 6221 of this title.

16. 2018

    Energy and Water Development and Related Agencies Appropriations Act, 2018

    Pub. L. 115–141 § 401(a)(281) · 132 Stat. 348

    Substituted · 26 U.S.C. § 6330(c)(4)

    Pub. L. 115–141, § 401(a)(281), substituted “subsection (d)(3)(B)” for “subsection (d)(2)(B)” in concluding provisions

    Source evidence

    Code amendment note
    Subsec. (c)(4). Pub. L. 115–141, § 401(a)(281), substituted “subsection (d)(3)(B)” for “subsection (d)(2)(B)” in concluding provisions.

    Enacted provision · exact public law section
    Sec. 401. The Nuclear Regulatory Commission shall comply with the July 5, 2011, version of Chapter VI of its Internal Commission Procedures when responding to Congressional requests for information.

17. 2018

    Energy and Water Development and Related Agencies Appropriations Act, 2018

    Pub. L. 115–141 § 401(a)(282) · 132 Stat. 348

    Substituted · 26 U.S.C. § 6330(d)(2)

    Pub. L. 115–141, § 401(a)(282), substituted “thereafter.” for “thereafter, and”

    Source evidence

    Code amendment note
    Subsec. (d)(2). Pub. L. 115–141, § 401(a)(282), substituted “thereafter.” for “thereafter, and”.

    Enacted provision · exact public law section
    Sec. 401. The Nuclear Regulatory Commission shall comply with the July 5, 2011, version of Chapter VI of its Internal Commission Procedures when responding to Congressional requests for information.

18. 2019

    Taxpayer First Act

    Pub. L. 116–25 § 1001(b)(1)(C) · 133 Stat. 981

    Substituted · 26 U.S.C. § 6330(b)(1)

    Pub. L. 116–25, § 1001(b)(1)(C), substituted “Internal Revenue Service Independent Office of Appeals” for “Internal Revenue Service Office of Appeals”

    Source evidence

    Code amendment note
    Subsec. (b)(1). Pub. L. 116–25, § 1001(b)(1)(C), substituted “Internal Revenue Service Independent Office of Appeals” for “Internal Revenue Service Office of Appeals”.

    Enacted provision · exact public law section
    (C) Subsections (b)(1) and (d)(3) of section 6330.

19. 2019

    Taxpayer First Act

    Pub. L. 116–25 title I § 1001(b)(1)(C) · 133 Stat. 981

    1. Inserted · 26 U.S.C. § 6330(d)(3)

       Pub. L. 116–25 inserted “Independent” after “IRS” in heading

    2. Substituted · 26 U.S.C. § 6330(d)(3)

       Pub. L. 116–25 substituted “Internal Revenue Service Independent Office of Appeals” for “Internal Revenue Service Office of Appeals” in introductory provisions

    Source evidence

    Code amendment note
    Subsec. (d)(3). Pub. L. 116–25 inserted “Independent” after “IRS” in heading and substituted “Internal Revenue Service Independent Office of Appeals” for “Internal Revenue Service Office of Appeals” in introductory provisions.

    Enacted provision · exact public law section
    (C) Subsections (b)(1) and (d)(3) of section 6330.

26 of 26 references resolved to an enrolled provision