Taxpayer Due Process Enhancement Act
Sponsored By: Representative Moran, Nathaniel [R-TX-1]
In Committee
Summary
This bill would strengthen taxpayer protections in IRS collection actions by limiting when the IRS can apply overpayments and aligning filing deadlines with the specific tax amounts actually disputed. It focuses on three changes that give taxpayers clearer rights during collections.
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- Households facing collection actions get tighter limits on deadline suspension. The bill would suspend the period to file a claim for credit or refund only for the portion of a claim tied to a tax amount that was properly disputed at a collection hearing. It also narrows suspensions so they do not stretch past court deadlines, filings, or orders that end a dispute.
- Taxpayers with overpayments would keep more control. The IRS could not automatically apply an overpayment to a tax liability that is being disputed during the suspended period unless the taxpayer agrees.
- People challenging IRS actions gain broader court review. The Tax Court would be able to review the collection determination, any underlying liability properly disputed at the hearing, and claims about equitable tolling of the 30-day deadline. Jurisdiction would continue even if the IRS stops the collection action.
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Bill Overview
Analyzed Economic Effects
1 provisions identified: 1 benefits, 0 costs, 0 mixed.
More protections for taxpayers in collection disputes
If enacted, this bill would pause the deadline to file a tax refund claim while you properly dispute a tax at a section 6320 or 6330 collection hearing. The pause would only cover the part of the refund tied to the disputed tax and would end if you miss a deadline or a court filing or order shows you lost the right to continue the dispute. While the pause is in effect, the IRS would not be able to apply your overpayment to that disputed tax without your consent. You would be able to file a Tax Court petition within 30 days to review the collection decision, the disputed tax, and any equitable tolling, and the court would keep jurisdiction even if the IRS later abandons the collection action. The timing rules apply to periods ending on or after enactment, and the change treating lien hearings like levy hearings would take effect on enactment.
Sponsors & CoSponsors
Sponsor
Moran, Nathaniel [R-TX-1]
TX • R
Cosponsors
Sewell
AL • D
Sponsored 12/9/2025
Roll Call Votes
No roll call votes available for this bill.
View on Congress.gov