§ 7432. Civil damages for failure to release lien
(a)
In general
If any officer or employee of the Internal Revenue Service knowingly, or by reason of negligence, fails to release a lien under section
6325 on property of the taxpayer, such taxpayer may bring a civil action for damages against the United States in a district court of the United States.
(b)
Damages
In any action brought under subsection (a), upon a finding of liability on the part of the defendant, the defendant shall be liable to the plaintiff in an amount equal to the sum of—
(d)
Limitations
(1)
Requirement that administrative remedies be exhausted
A judgment for damages shall not be awarded under subsection (b) unless the court determines that the plaintiff has exhausted the administrative remedies available to such plaintiff within the Internal Revenue Service.
(e)
Notice of failure to release lien
The Secretary shall by regulation prescribe reasonable procedures for a taxpayer to notify the Secretary of the failure to release a lien under section
6325 on property of the taxpayer.