Referred to the House Committee on Ways and Means.
This bill ("Taxpayer Due Process Enhancement Act") amends the Internal Revenue Code to adjust rules around collection hearings, refund claim limitations, and Tax Court jurisdiction. It suspends limitation periods for refund claims only to the extent an underlying liability is properly disputed at a timely hearing, and prevents the IRS from crediting taxpayer overpayments against such disputed liabilities while that suspension applies unless the taxpayer consents.
Due process protections for taxpayers versus IRS enforcement efficiency
Relative to its intended legislative type, this bill is a well-specified substantive modification to the Internal Revenue Code that uses targeted statutory amendments to change taxpayer and administrative rights and procedures while also adjusting judicial review paths.
This bill ("Taxpayer Due Process Enhancement Act") amends the Internal Revenue Code to adjust rules around collection hearings, refund claim limitations, and Tax Court jurisdiction.
It suspends limitation periods for refund claims only to the extent an underlying liability is properly disputed at a timely hearing, and prevents the IRS from crediting taxpayer overpayments against such disputed liabilities while that suspension applies unless the taxpayer consents.
The measure also clarifies that certain levy-hearing rules apply to lien hearings, and expands Tax Court jurisdiction to review properly disputed underlying tax liabilities and equitable tolling of the 30-day petition deadline.
Technically focused and non‑ideological but expands litigation avenues and may provoke Treasury/IRS fiscal and resource objections; lacks explicit cost estimates.
Relative to its intended legislative type, this bill is a well-specified substantive modification to the Internal Revenue Code that uses targeted statutory amendments to change taxpayer and administrative rights and procedures while also adjusting judicial review paths.
Due process protections for taxpayers versus IRS enforcement efficiency
These are examples from the analysis, not a ranked list of the most-affected groups.
Due process protections for taxpayers versus IRS enforcement efficiency
Likely to view the bill positively as strengthening taxpayer due process and preventing premature taking of refunds during disputes.
The expansion of Tax Court jurisdiction and limits on applying overpayments are seen as protections for low- and middle-income taxpayers facing aggressive collection.
Support would be strong if implementation resources and access for vulnerable taxpayers are addressed.
Generally sympathetic to improving due process and clarifying procedures, but cautious about administrative costs and unintended delays in revenue collection.
Views changes as reasonable if paired with limits to prevent abuse and with resources for timely adjudication.
Would favor monitored implementation and possible guardrails.
Likely to view the bill skeptically as tilting procedural advantage toward taxpayers and constraining IRS enforcement.
Concerns center on interruption of collection tools, expanded judicial review, and incentives for frivolous disputes.
Would prefer stronger safeguards for tax administration and limits on expanded taxpayer rights.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Technically focused and non‑ideological but expands litigation avenues and may provoke Treasury/IRS fiscal and resource objections; lacks explicit cost estimates.
The bill has not accumulated any surfaced votes yet.
Due process protections for taxpayers versus IRS enforcement efficiency
Technically focused and non‑ideological but expands litigation avenues and may provoke Treasury/IRS fiscal and resource objections; lacks e…
Relative to its intended legislative type, this bill is a well-specified substantive modification to the Internal Revenue Code that uses targeted statutory amendments to change taxpayer and administrative rights and pro…
Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.