26 U.S.C. § 7401
Section 7401 · Authorization
Amended 2 times on record
Applied in 209 court decisions — leading case United States v. Chila (1989)
Most recently applied in United States of America v. P Frederick J. Fuller, et al. (August 2023)
Cases citing this section usually also cite 28 U.S.C. § 1340 · 26 U.S.C. § 7402 · 26 U.S.C. § 6321
How often courts cite this section
Court decisions citing this, by year.Markers show enactment and consequential amendments — watch for a citation surge after a change. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
No civil action for the collection or recovery of taxes, or of any fine, penalty, or forfeiture, shall be commenced unless the Secretary authorizes or sanctions the proceedings and the Attorney General or his delegate directs that the action be commenced.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Amendments
1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary”.