PROOF Act
Sponsored By: Representative Doggett, Lloyd [D-TX-37]
Introduced
Summary
A new, rights-based examination process for most tax-exempt organizations. This bill would create a staged, transparent framework for IRS examinations of 501(a) entities other than churches and add clearer notice, record, conference, and appeal rules.
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Bill Overview
Analyzed Economic Effects
2 provisions identified: 2 benefits, 0 costs, 0 mixed.
More due-process for nonprofit audits
This bill would create new due-process rules for IRS exams of organizations exempt under section 501(a), except churches. The IRS would have to send a written notice before starting an exam that names the examiner and supervisor, lists the tax years and issues, explains rights to representation, and offers to consider a written response or hold an opening conference. Document requests would have to describe each required record, explain why it relates to the exam, and give at least 30 days to respond; deficient requests could not be used to support an adverse denial of tax-exempt status. The IRS would need to keep a formal case record, offer supervisory and closing conferences with written summaries, provide a proposed adverse-determination letter and wait at least 30 days before issuing a final adverse determination, and, after the record is complete or a protest is filed, give the organization its exam record within 30 days subject to privilege exceptions. These rules would apply to examinations begun after December 31, 2024.
More notice rights for churches
This bill would change IRS exam notices for churches. Notices would have to explain a church's rights, including the right to legal representation and the right to request a supervisory conference. Notices would also have to offer to consider a written response, not only a conference. If the IRS expands the scope of a church exam, it would have to send a supplemental written notice describing the church records and activities sought. These rules would apply to examinations begun after December 31, 2024.
Sponsors & CoSponsors
Sponsor
Doggett, Lloyd [D-TX-37]
TX • D
Cosponsors
Rep. Sewell, Terri A. [D-AL-7]
AL • D
Sponsored 9/3/2026
Roll Call Votes
No roll call votes available for this bill.
View on Congress.gov