# 119-s-1386: Small Business Taxpayer Bill of Rights Act of 2025 119-s-1386, Small Business Taxpayer Bill of Rights Act of 2025, is a 119th Congress bill sponsored by Sen. Cornyn, John [R-TX] (R-TX); status introduced; PRIA reads it as touching household money (as of 2026-04-21). - Canonical: https://policyrisk.com/legislation/119-s-1386 - As of: 2026-04-21 - Plain-text twin of the page above; the HTML and this file carry the same facts. ## Facts - Bill: 119-s-1386 - Congress: 119 - Title: Small Business Taxpayer Bill of Rights Act of 2025 - Status: introduced - Introduced: 2025-04-09 - Sponsor: Sen. Cornyn, John [R-TX] (R-TX) - Cosponsors: 0 - Policy area: Taxation - Touches household money: yes - Last recorded action: 2026-04-21 ## Summary **This bill would strengthen taxpayer and small-business protections** by increasing remedies against IRS misconduct and limiting certain enforcement actions. It also expands dispute-resolution rights and tightens oversight of appeals and IRS personnel. - Small businesses would find it easier to recover legal costs because the bill removes the net-worth cap for cost awards and defines eligible firms as those with average annual gross receipts up to $50 million. It would also repeal the partial-payment requirement for offers-in-compromise and make mediation or arbitration broadly available with income-based fee relief. - Homeowners and families would get stronger protection from collection actions because the IRS could not target a taxpayer's principal residence unless other assets are insufficient and the action would not create economic hardship, with senior officials required to approve such steps. - Taxpayers would gain bigger damages and longer filing windows for IRS harms; caps for reckless misconduct rise to $5 million and damages for unauthorized disclosures to $10,000, and the statute of limitations extends to 5 years. The bill would ban ex parte contacts in the Independent Office of Appeals, create a right to an independent appeals conference, increase penalties for IRS officer misconduct, and require expanded TIGTA reviews of potentially discriminatory selection criteria. ## Provisions PRIA read - Higher damage limits for taxpayers: benefit, high. This bill would raise civil damage caps for IRS misconduct to $5,000,000 for reckless or intentional disregard and $500,000 for negligence. It would raise per-incident privacy damages to $10,000 for unauthorized inspections or disclosures. The time to sue would increase from 2 years to 5 years. The… - Tax deduction for audit costs: benefit, high. This bill would create an above-the-line deduction of up to $5,000 for qualifying expenses from a National Research Program audit if the audit results in no increase in tax for that year. The deduction could not be claimed under any other tax rule. This would apply to tax years after enactment. - More fair and independent IRS Appeals: benefit, medium. This bill would bar off-the-record talks between Appeals officers and other IRS staff. Appeals could not add new issues outside the initial determination. Taxpayers could elect independent mediation or arbitration, with mediator fees split and waivers for low-income individuals and some small busin… - Protecting your home from tax seizure: benefit, medium. This bill would bar using your principal residence to satisfy a tax lien unless the Treasury Secretary writes that selling all other property is insufficient and the action will not create economic hardship. The Secretary could delegate that decision only to top IRS officials. The bill would also r… - Small business levy and fee protections: benefit, medium. This bill would require the IRS to consider a business's economic viability before refusing to release a levy. The IRS must weigh hardship, whether the taxpayer used ordinary business care, and harm to employees if the business is liquidated. It would also let more small businesses recover legal co… - Stricter penalties and firings for IRS staff: mixed, medium. This bill would raise fines for certain IRS officer offenses to $25,000 in one category and $10,000 in another, with future inflation indexing. It would require termination after a final finding of certain misconduct, or allow the Commissioner to take other non-appealable personnel actions. Some pe… ## Related bills - 119-s-1071: National Defense Authorization Act for Fiscal Year 2026 - 119-s-4952: Protecting American Taxpayers Act - 119-s-4378: Protecting American Taxpayers Act - 119-s-1748: Kids Online Safety Act - 119-s-4726: PEACE in Sudan Act - 119-s-4065: STAND with Taiwan Act of 2026 ## Sources - [119-s-1386 on Congress.gov](https://www.congress.gov/bill/119th-congress/senate-bill/1386) ## Related - [119-s-1071: National Defense Authorization Act for Fiscal Year 2026](https://policyrisk.com/legislation/119-s-1071) - [119-s-4952: Protecting American Taxpayers Act](https://policyrisk.com/legislation/119-s-4952) - [119-s-4378: Protecting American Taxpayers Act](https://policyrisk.com/legislation/119-s-4378) - [119-s-1748: Kids Online Safety Act](https://policyrisk.com/legislation/119-s-1748) - [119-s-4726: PEACE in Sudan Act](https://policyrisk.com/legislation/119-s-4726) - [119-s-4065: STAND with Taiwan Act of 2026](https://policyrisk.com/legislation/119-s-4065) - [All bills in Congress](https://policyrisk.com/legislation) Source: PRIA, https://policyrisk.com/legislation/119-s-1386 (as of 2026-04-21).