26 U.S.C. § 7432 — Civil damages for failure to release lien
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“(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.”
the costs of the action.
(c) Payment authority
Claims pursuant to this section shall be payable out of funds appropriated under section 1304 of title 31, United States Code.
(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.
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