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HR6506119th CongressWALLET

Taxpayer Due Process Enhancement Act

Sponsored By: Representative Moran, Nathaniel [R-TX-1]

Passed House

Summary

This bill would strengthen protections for taxpayers disputing IRS collection by clarifying when refund deadlines pause and by expanding Tax Court review. It tightens the rules that pause the time to file claims for credits or refunds and limits when the IRS can apply overpayments to disputed debts, while giving taxpayers a clearer route to challenge collection in Tax Court.

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  • Taxpayers who challenge a proposed levy or lien would see the suspension of the deadline to file a claim for credit or refund apply only to the portion of the refund tied to the tax properly disputed at the hearing, and the pause ends if the taxpayer forfeits the dispute.
  • Taxpayers with overpayments would be protected from having those payments automatically credited against a disputed tax during the suspension period unless they consent.
  • Taxpayers and practitioners get broader Tax Court access. A petition may seek review within 30 days of a determination and can include the underlying disputed liability and equitable tolling, and the court keeps jurisdiction even if the IRS abandons collection.

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Bill Overview

Analyzed Economic Effects

3 provisions identified: 2 benefits, 0 costs, 1 mixed.

Tax Court review of disputed taxes

You would be able to ask the Tax Court to review both the collection decision and any underlying tax you properly disputed at the hearing. You would need to file within 30 days of the IRS collection hearing determination. The court would also be able to decide whether the 30‑day deadline should be extended. The court would keep the case even if the IRS drops the collection action. This would apply to petitions filed after enactment.

Refund pause, no offsets during IRS appeals

If you properly request a collection hearing and dispute the tax, the deadline to file a refund claim for that part would pause. The pause would end if you miss a deadline, file in court, or a court order says you lost the right to keep fighting it. While the pause is in effect, the IRS would not use your overpayment to pay that disputed tax unless you agree. These rules would apply to periods that end on or after enactment, and to any offset period that includes time after enactment.

Same hearing rules for liens and levies

If you face a lien or another collection action, you would be able to raise the same issues you could at a levy hearing. This clarification would take effect on enactment.

Sponsors & CoSponsors

Sponsor

Moran, Nathaniel [R-TX-1]

TX • R

Cosponsors

  • Rep. Sewell, Terri A. [D-AL-7]

    AL • D

    Sponsored 12/9/2025

Roll Call Votes

No roll call votes available for this bill.

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