§ 7491. Remedy exclusive; determination final

(a) The exclusive remedy of a taxpayer with respect to the refund of monies paid in connection with a return filed under this chapter shall be the petition for refund provided under section 7488 of this title, and the appeal from an adverse determination of the petition for refund provided under section 7489 of this title. The exclusive remedy of a taxpayer with respect to a notification of deficiency or assessment of penalty or interest under sections 3202 and 3203 of this title shall be the petition for determination of the deficiency or assessment provided under section 7487 of this title, and the appeal from an adverse determination of deficiency or assessment provided under section 7489 of this title.

(b) Upon the failure of a taxpayer to petition in accordance with section 7487 of this title from a notice of deficiency or assessment under sections 3202 and 3203 of this title, or to appeal in accordance with section 7489 of this title from a determination of a deficiency of assessment of tax liability under section 7487 of this title, the taxpayer shall be bound by the terms of the notification, assessment, or determination, as the case may be. The taxpayer shall not thereafter contest, either directly or indirectly, the tax liability as therein set forth, in any proceeding including a proceeding upon a claim of refund of all or any part of any payment made with respect to the tax liability, or a proceeding for the enforcement or collection of all or any part of the tax liability. (Added 1969, No. 269 (Adj. Sess.), § 1, eff. date, see note under § 7401 of this title; amended 2017, No. 113 (Adj. Sess.), § 193.)