What does Preamble of Taxpayer Due Process Enhancement Act do?

This bill amends the Internal Revenue Code of 1986. It suspends the period of limitations on filing a claim for credit or refund during collection action proceedings. The bill prohibits crediting overpayments against disputed tax liability during collection action proceedings. It expands the jurisdiction of the Tax Court.

What does SHORT TITLE. of Taxpayer Due Process Enhancement Act do?

This bill is formally titled Taxpayer Due Process Enhancement Act

What does SUSPENSION OF PERIOD OF LIMITATIONS ON FILING A CLAIM FOR of Taxpayer Due Process Enhancement Act do?

This section amends Section 6330(e)(1) of the Internal Revenue Code of 1986 to include references to sections 6511(a), (b), or (c) regarding limitations on credit or refund. It adds a new paragraph (3) to Section 6330(e) which addresses the period of limitations on filing a claim for credit or refund during collection action proceedings. This new paragraph limits the application of paragraph (1) to credits or refunds related to a properly disputed underlying tax liability. The period of limitations will not be suspended after a taxpayer forfeits their right to dispute the liability. Section 6511(i) of the Internal Revenue Code is amended to include a cross-reference to Section 6330(e) regarding limitations in collection action proceedings. The amendments apply to periods of limitations ending on or after the date of enactment of this Act.

What does PROHIBITION ON CREDITING OF OVERPAYMENTS AGAINST DISPUTED TAX of Taxpayer Due Process Enhancement Act do?

This section amends Section 6402 of the Internal Revenue Code of 1986 by adding a new subsection (o). The new subsection prohibits crediting overpayments against a disputed tax liability during collection action proceedings if a hearing is requested under sections 6320(a)(3)(B) or 6330(a)(3)(B). Such tax liability shall not be taken into account unless the taxpayer consents. The prohibition applies during the period the statute of limitations for a refund claim is suspended. Section 6330(c)(2)(A) of the Internal Revenue Code is amended to include 'collection action, or proposed collection action' alongside 'unpaid tax'. The amendment in subsection (a) applies to periods after the enactment of this Act. The amendment in subsection (b) takes effect on the date of enactment.

What does EXPANSION OF JURISDICTION OF TAX COURT. of Taxpayer Due Process Enhancement Act do?

This section amends Section 6330(d)(1) of the Internal Revenue Code of 1986. It allows a person to petition the Tax Court for review of a determination and any related tax liability within 30 days of the determination. The Tax Court will have jurisdiction over the determination, the underlying tax liability, and any equitable tolling of the 30-day deadline. These provisions apply regardless of whether the Secretary abandons a collection action. The amendment is effective for petitions filed after the date of enactment of this Act.

Back to bills

Taxpayer Due Process Enhancement Act

Last updated: 5/20/2026 · Introduced: 12/9/2025

Author: Nathaniel Moran (R-TX)

TL;DR (AI)

This bill suspends the statute of limitations for claiming tax refunds or credits during collection actions, but only if the underlying tax liability is properly disputed and the taxpayer hasn't forfeited their right to dispute it.
The bill prevents the IRS from applying overpayments to disputed tax liabilities during collection actions unless the taxpayer consents, particularly when a hearing has been requested.
This legislation expands the Tax Court's jurisdiction to include review of tax determinations and related liabilities, allowing taxpayers to petition the court within 30 days of the determination.

119th Congresspassed houseOfficial page

Verified Votes

No verified votes yet.

Community Votes

No community votes yet. Be the first!

Voting as guest · Sign in for verified votes

Other Sections

Includes provisions on preamble, short title., and 3 more.

5 sections

Click "Show details" to explore individual sections. Use the community vote above or visit All Sections to vote per section.

Read official text

Want the full experience?

Create a free account to cast verified votes on each section, get a personalized summary, and track your voting history.

Create Free Account