Taxpayer Due Process Enhancement Act

Bill Number: H.R. 6506
Origin Chamber: House
Congress: 119th Congress, Session 2
Policy Area: Taxation
Status: Passed House
Latest Action: 2026-05-20: Received in the Senate and Read twice and referred to the Committee on Finance.
Last Updated: 2026-06-11T05:06:24Z

AI-Generated Summary

Purpose This legislation, titled the Taxpayer Due Process Enhancement Act, aims to strengthen taxpayer protections during Internal Revenue Service collection proceedings by adjusting rules on tax refund claims, overpayment credits, and court review options.

Key Provisions

Suspends the usual time limits for filing refund claims while a taxpayer disputes a tax liability in a collection due process hearing.
Prevents the IRS from automatically applying a taxpayer’s overpayments to a disputed tax bill during these hearings, unless the taxpayer agrees.
Expands the U.S. Tax Court’s authority to review both the IRS determination and the underlying disputed tax liability, including the possibility of extending filing deadlines in certain cases.
Maintains Tax Court jurisdiction even if the IRS later drops the collection action.

Significant Changes to Existing Law

Modifies Section 6330 of the Internal Revenue Code to pause refund claim deadlines during collection hearings and limits suspension to properly disputed liabilities.
Adds a new subsection to Section 6402 that blocks crediting overpayments against disputed amounts while refund claim periods are suspended.
Broadens Section 6330(d) to give the Tax Court explicit power over underlying tax issues and equitable tolling of deadlines, rather than limiting review to the IRS determination alone.

Potential Impacts

On government agencies: The IRS may face longer processing times for disputed cases and must adjust procedures for handling overpayments and collection actions.
On citizens: Taxpayers gain additional time and flexibility to challenge tax liabilities without losing refund rights or facing automatic offsets.
On international relations: No direct effects identified in the legislation.

Main Stakeholders Affected

Taxpayers involved in IRS collection disputes.
The Internal Revenue Service and its enforcement operations.
The U.S. Tax Court, which gains expanded review responsibilities.
Tax professionals and legal representatives assisting with disputes.

Notable Legal, Constitutional, or Political Implications The bill reinforces due process protections in tax collection by clarifying court access and preventing certain IRS actions during disputes. It does not alter constitutional rights but formalizes procedural safeguards within the existing tax code framework.

This summary was generated by AI and may contain inaccuracies. Refer to the official source document for the authoritative text.

Sponsor

Rep. Moran, Nathaniel [R-TX-1]

Cosponsors (1)

Rep. Sewell, Terri A. [D-AL-7]

Recent Actions

2026-05-20: Received in the Senate and Read twice and referred to the Committee on Finance.
2026-05-19: Motion to reconsider laid on the table Agreed to without objection.
2026-05-19: On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564)
2026-05-19: Passed/agreed to in House: On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564)
2026-05-19: DEBATE - The House proceeded with forty minutes of debate on H.R. 6506.
2026-05-19: Considered under suspension of the rules. (consideration: CR H3564-3567)
2026-05-19: Mr. Smith (MO) moved to suspend the rules and pass the bill, as amended.
2026-01-07: Placed on the Union Calendar, Calendar No. 373.
2026-01-07: Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.
2026-01-07: Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.
2025-12-10: Ordered to be Reported in the Nature of a Substitute (Amended) by the Yeas and Nays: 41 - 0.
2025-12-10: Committee Consideration and Mark-up Session Held
2025-12-09: Referred to the House Committee on Ways and Means.
2025-12-09: Introduced in House
2025-12-09: Introduced in House

Bill Versions

Taxpayer Due Process Enhancement Act — issued 2026-05-19 — PDF (8 pages)
Taxpayer Due Process Enhancement Act — issued 2025-12-09 — PDF (6 pages)
Taxpayer Due Process Enhancement Act — issued 2026-05-20 — PDF (6 pages)
Taxpayer Due Process Enhancement Act — issued 2026-01-07 — PDF (8 pages)