§6406 — Prohibition of administrative review of decisions
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Statute Text — 26 U.S.C. §6406
In the absence of fraud or mistake in mathematical calculation, the findings of fact in and the decision of the Secretary upon the merits of any claim presented under or authorized by the internal revenue laws and the allowance or non-allowance by the Secretary of interest on any credit or refund under the internal revenue laws shall not, except as provided in subchapters C and D of chapter 76 (relating to the Tax Court), be subject to review by any other administrative or accounting officer, employee, or agent of the United States.
1 Citing Cases
Petitioner asserts that, because of previous abatement of $867.92 in late filing penalties, section 6406 operates to estop respondent from assessing $16,494 in late filing penalties that were subsequently determined in the notice of deficiency for 1995.