TaxGuided
United States IRC sections

Statute section

IRC section 6330

Notice and opportunity for hearing before levy (Collection Due Process)

Country

United States

Section

6330

Updated

2026-05-20

Operative text

Section 6330 provides procedural rights to taxpayers before the IRS levies on property to collect tax. A taxpayer may request a Collection Due Process hearing and petition the Tax Court for review within 30 days of the determination. The Supreme Court held the 30-day deadline is non-jurisdictional and subject to equitable tolling in Boechler v. Commissioner (2022).

Cross-references

26 U.S.C. 6320

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Primary sources

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