26 U.S.C. § 6303
Section 6303 · Notice and demand for tax
Amended 2 times on record
Applied in 314 court decisions — leading case Wiley v. United States (1994)
Most recently applied in United States v. Ronald Byers (April 2025)
Applied most in the Ninth Circuit Circuit (49 decisions)
Cases citing this section usually also cite 26 U.S.C. § 6203 · 26 U.S.C. § 6321 · 26 U.S.C. § 6213
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. 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.
Where it is not otherwise provided by this title, the Secretary shall, as soon as practicable, and within 60 days, after the making of an assessment of a tax pursuant to section 6203, give notice to each person liable for the unpaid tax, stating the amount and demanding payment thereof. Such notice shall be left at the dwelling or usual place of business of such person, or shall be sent by mail to such person's last known address.
Except where the Secretary believes collection would be jeopardized by delay, if any tax is assessed prior to the last date prescribed for payment of such tax, payment of such tax shall not be demanded under subsection (a) until after such date.
Editorial notes U.S. Code · Office of the Law Revision Counsel
Amendments
1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary” wherever appearing.
Cross References
Interest payable on notice and demand, see section 6601 of this title.
Levy and distraint within ten days after notice and demand, see section 6331 of this title.
Notice and demand to delinquent internal revenue officer and employee, see section 7803 of this title.
Payment on notice and demand, see section 6155 of this title.