Protecting Taxpayers Act
This bill modifies the organizational structure, management practices, and enforcement procedures of the Internal Revenue Service (IRS).
The bill modifies policies regarding:
[Congressional Bills 115th Congress]
[From the U.S. Government Publishing Office]
[S. 3278 Introduced in Senate (IS)]
<DOC>
115th CONGRESS
2d Session
S. 3278
To amend the Internal Revenue Code of 1986 to provide additional
protections to taxpayers.
_______________________________________________________________________
IN THE SENATE OF THE UNITED STATES
July 26, 2018
Mr. Portman (for himself and Mr. Cardin) introduced the following bill;
which was read twice and referred to the Committee on Finance
_______________________________________________________________________
A BILL
To amend the Internal Revenue Code of 1986 to provide additional
protections to taxpayers.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE; TABLE OF CONTENTS.
(a) Short Title.--This Act may be cited as the ``Protecting
Taxpayers Act''.
(b) Table of Contents.--The table of contents of this Act is as
follows:
Sec. 1. Short title; table of contents.
Sec. 2. Amendment of Internal Revenue Code of 1986.
TITLE I--MANAGEMENT AND TRAINING
Sec. 101. Internal Revenue Service Management Board.
Sec. 102. Comprehensive training strategy.
Sec. 103. Streamlining centralized training program approval.
TITLE II--TAXPAYER PROTECTION
Sec. 201. Quarterly notices of delinquency.
Sec. 202. Regulation of tax return preparers.
Sec. 203. Misdirected tax refund deposits.
TITLE III--SMALL BUSINESS TAX ADMINISTRATION AND COMPLIANCE
Sec. 301. Safe harbor for employer tip reporting.
Sec. 302. Information reporting of income from certain rentals of space
in the beauty service industry.
Sec. 303. Release of Federal tax levies which cause business hardship.
Sec. 304. Extension of time for making S corporation elections.
Sec. 305. Quarterly reporting of estimated tax payments.
TITLE IV--RETIREMENT PLANS AND SAVINGS
Sec. 401. Expansion of employee plans compliance resolution system.
TITLE V--ASSISTANCE FOR LOW-INCOME TAXPAYERS
Sec. 501. Establishment of income threshold for referral to private
debt collection.
Sec. 502. Return preparation programs for applicable taxpayers.
Sec. 503. Low-income taxpayer clinics.
Sec. 504. Low-income exception for payments otherwise required in
connection with a submission of an offer-
in-compromise.
TITLE VI--APPEALS PROCESS
Sec. 601. Right to independent conference.
Sec. 602. Access to case files.
Sec. 603. Ensuring taxpayer right to appeal.
Sec. 604. Limitation on designation of cases as not eligible for
referral to Independent Office of Appeals.
Sec. 605. Procedures related to Secretarial authority to designate
cases for litigation.
TITLE VII--MISCELLANEOUS
Sec. 701. Modification of authority to issue designated summons.
Sec. 702. Streamlined critical pay authority for information technology
positions.
Sec. 703. Uniform standards for the use of electronic signatures for
disclosure authorizations to, and other
authorizations of, practitioners.
Sec. 704. Limitation on access of non-Internal Revenue Service
employees to returns and return
information.
SEC. 2. AMENDMENT OF INTERNAL REVENUE CODE OF 1986.
Except as otherwise expressly provided, whenever in this Act an
amendment or repeal is expressed in terms of an amendment to, or repeal
of, a section or other provision, the reference shall be considered to
be made to a section or other provision of the Internal Revenue Code of
1986.
TITLE I--MANAGEMENT AND TRAINING
SEC. 101. INTERNAL REVENUE SERVICE MANAGEMENT BOARD.
(a) In General.--Section 7802 is amended--
(1) in the heading, by striking ``oversight board'' and
inserting ``management board'',
(2) by striking ``Oversight Board'' each place it appears
and inserting ``Management Board'',
(3) in subsection (b)--
(A) in paragraph (1)--
(i) in subparagraph (A), by striking
``six'' and inserting ``four'',
(ii) by striking subparagraph (B) and
inserting the following:
``(B) one non-voting member shall be the Deputy
Secretary of the Treasury.'',
(iii) in subparagraph (C), by inserting
``non-voting'' before ``member'', and
(iv) by adding at the end the following new
subparagraph:
``(E) one non-voting member shall be the Deputy
Inspector General for Tax Administration.'',
(B) in paragraph (4), by striking ``Five members''
and inserting ``Three voting members'', and
(C) in paragraph (5), by striking subparagraph (B)
and inserting the following:
``(B) Ex officio members.--An individual described
in subparagraph (B), (C), or (E) of paragraph (1) shall
be removed upon termination of service in the office
described in such subparagraph.'',
(4) in subsection (c)(1)(B), by inserting ``and that all
employees of the Internal Revenue Service are familiar with and
act in accordance with the Taxpayer Bill of Rights'' before the
period, and
(5) in subsection (d)--
(A) in paragraph (1)--
(i) in subparagraph (A), by striking
``and'' at the end,
(ii) by striking subparagraph (B) and
inserting the following:
``(B) long-range strategic plans, and'', and
(iii) by adding at the end the following:
``(C) an annual performance report and plan.'',
(B) in paragraph (3)--
(i) in subparagraph (B)--
(I) by striking ``selection,
evaluation, and compensation'' and
inserting ``selection and evaluation'',
and
(II) by striking ``and'' at the
end,
(ii) by redesignating subparagraph (C) as
subparagraph (D), and
(iii) by inserting after subparagraph (B)
the following:
``(C) review and approve the Commissioner's
compensation of Internal Revenue Service senior
executives described in subparagraph (B); and'',
(C) in paragraph (4)--
(i) in subparagraph (B), by striking
``and'' at the end,
(ii) by redesignating subparagraph (C) as
subparagraph (D), and
(iii) by inserting after subparagraph (B)
the following:
``(C) review any changes made to such budget
request by the Office of Management and Budget prior to
submission of the President's annual budget request to
Congress; and'', and
(D) by inserting after paragraph (5) the following:
``(6) Audits.--To direct the Treasury Inspector General for
Tax Administration to perform an audit of any programs or
operations of the Internal Revenue Service.''.
(b) Conforming Amendments.--
(1) Section 4946(c)(7) is amended by striking ``Oversight
Board'' and inserting ``Management Board''.
(2) Paragraph (6) of section 6103(h) is amended--
(A) in the heading, by striking ``Oversight board''
and inserting ``Management board'', and
(B) by striking ``Oversight Board'' each place it
appears and inserting ``Management Board''.
(3) Section 7803 is amended--
(A) in subsection (a)(4), by striking ``Oversight
Board'' and inserting ``Management Board'', and
(B) in subsection (c)--
(i) in paragraph (1)(B)(ii), by striking
``Oversight Board'' and inserting ``Management
Board'', and
(ii) in paragraph (2)(B)(iii), by striking
``Oversight Board'' and inserting ``Management
Board''.
(c) Effective Date.--The amendments made by this section shall take
effect on the date of the enactment of this Act.
SEC. 102. COMPREHENSIVE TRAINING STRATEGY.
Not later than 1 year after the date of the enactment of this Act,
the Commissioner of Internal Revenue, in consultation with the National
Taxpayer Advocate, shall submit to Congress a written report providing
a comprehensive training strategy for employees of the Internal Revenue
Service, including--
(1) a plan to streamline current training processes,
including an assessment of the utility of further consolidating
internal training programs, technology, and funding,
(2) a plan to develop annual training regarding taxpayer
rights, including the role of the Office of the Taxpayer
Advocate,
(3) a plan to improve technology-based training, including
by developing or adopting state-of-the-art training delivery
methods,
(4) proposals to focus employee training on early, fair,
and efficient resolution of taxpayer disputes and to ensure
consistency of skill development and employee evaluation
throughout the Internal Revenue Service,
(5) recommendations for improvement of employee
recruitment, and
(6) a thorough assessment of the funding necessary to
implement such strategy.
SEC. 103. STREAMLINING CENTRALIZED TRAINING PROGRAM APPROVAL.
The Secretary of the Treasury, or the Secretary's delegate, shall
modify the policy promulgated under Treasury Directive 12-70 to permit
employee training events (as defined by the Secretary or the
Secretary's delegate) for employees of the Internal Revenue Service,
the cost to the Internal Revenue Service of which exceeds $249,999 (but
does not exceed $500,000), to be approved by a Deputy Commissioner of
Internal Revenue.
TITLE II--TAXPAYER PROTECTION
SEC. 201. QUARTERLY NOTICES OF DELINQUENCY.
(a) In General.--Section 7524 is amended--
(1) in the heading, by striking ``annual'' and inserting
``quarterly'', and
(2) by striking ``annually'' and inserting ``each calendar
quarter''.
(b) Effective Date.--The amendments made by this section shall
apply to any calendar quarter beginning after December 31, 2018.
SEC. 202. REGULATION OF TAX RETURN PREPARERS.
(a) In General.--Subsection (a) of section 330 of title 31, United
States Code, is amended--
(1) by striking paragraph (1) and inserting the following:
``(1) regulate--
``(A) the practice of representatives of persons
before the Department of the Treasury; and
``(B) the practice of tax return preparers; and'',
and
(2) in paragraph (2)--
(A) by inserting ``or a tax return preparer to
prepare tax returns'' after ``practice'',
(B) by inserting ``or tax return preparer'' before
``demonstrate'', and
(C) by inserting ``or in preparing their tax
returns, claims for refund, or documents in connection
with tax returns or claims for refund'' after ``cases''
in subparagraph (D).
(b) Authority To Sanction Regulated Tax Return Preparers.--
Subsection (c) of section 330 of title 31, United States Code, is
amended--
(1) by striking ``before the Department'',
(2) by inserting ``or tax return preparer'' after
``representative'' each place it appears, and
(3) in paragraph (4), by striking ``misleads or threatens''
and all that follows and inserting ``misleads or threatens--
``(A) any person being represented or any
prospective person being represented; or
``(B) any person or prospective person whose tax
return, claim for refund, or document in connection
with a tax return or claim for refund, is being or may
be prepared.''.
(c) Minimum Competency Standards for Tax Return Preparers.--Section
330 of title 31, United States Code, is amended by adding at the end
the following new subsection:
``(f) Tax Return Preparers.--
``(1) In general.--Any tax return preparer shall
demonstrate minimum competency standards under this subsection
by--
``(A) obtaining an identifying number for securing
proper identification of such preparer as described in
section 6109(a)(4) of the Internal Revenue Code of
1986;
``(B) satisfying any examination and annual
continuing education requirements as prescribed by the
Secretary; and
``(C) completing a background check administered by
the Secretary.
``(2) Exemption.--The Secretary shall exempt tax return
preparers who have been subject to comparable examination,
continuing education requirements, and background checks
administered by the Secretary or any comparable State licensing
program. Such exemption shall extend directly to individuals
who are supervised by such preparers and are not required to
secure an identification number under section 6109(a)(4).''.
(d) Tax Return Preparer Defined.--Section 330 of title 31, United
States Code, as amended by subsection (c), is amended by adding at the
end the following new subsection:
``(g) Tax Return Preparer.--For purposes of this section--
``(1) In general.--The term `tax return preparer' has the
meaning given such term under section 7701(a)(36) of the
Internal Revenue Code of 1986.
``(2) Tax return.--The term `tax return' has the meaning
given to the term `return' under section 6696(e)(1) of the
Internal Revenue Code of 1986.
``(3) Claim for refund.--The term `claim for refund' has
the meaning given such term under section 6696(e)(2) of such
Code.''.
(e) Amendments With Respect to Identifying Number.--
(1) In general.--Section 6109(a) is amended by striking
paragraph (4) and inserting the following:
``(4) Furnishing identifying number of tax return
preparer.--
``(A) In general.--Any return or claim for refund
prepared by a tax return preparer shall bear such
identifying number for securing proper identification
of such preparer, his employer, or both, as may be
prescribed. For purposes of this paragraph, the terms
`return' and `claim for refund' have the respective
meanings given to such terms by section 6696(e).
``(B) Exception.--Subparagraph (A) shall not apply
to any tax return preparer who prepares a return or
claim for refund under the supervision and direction of
a tax return preparer who signs the return or claim for
refund and is a certified public accountant, an
attorney or enrolled agent.''.
(2) Clarification of rescission authority.--Section 6109 is
amended by inserting after subsection (d) the following new
subsection:
``(e) Authority To Rescind Identifying Number of Tax Return
Preparer.--
``(1) In general.--The Secretary may rescind an identifying
number issued under subsection (a)(4) if--
``(A) after notice and opportunity for a hearing,
the preparer is shown to be incompetent or disreputable
(as such terms are used in subsection (c) of section
330 of title 31, United States Code), and
``(B) rescinding the identifying number would
promote compliance with the requirements of this title
and effective tax administration.
``(2) Records.--If an identifying number is rescinded under
paragraph (1), the Secretary shall place in the file in the
Office of the Director of Professional Responsibility the
opinion of the Secretary with respect to the determination,
including--
``(A) a statement of the facts and circumstances
relating to the determination, and
``(B) the reasons for the rescission.''.
(f) GAO Study and Report on the Exchange of Information Between the
IRS and State Taxation Authorities.--
(1) In general.--Not later than 18 months after the date of
the enactment of this Act, the Comptroller General shall
conduct a study and submit to Congress a report on the sharing
of information between the Secretary of the Treasury and State
authorities, as authorized under section 6103(d) of the
Internal Revenue Code of 1986, regarding identification numbers
issued to paid tax return preparers and return preparer minimum
standards.
(2) Increased information sharing.--The study and report
described in paragraph (1) shall include an analysis of the
impact that increased information sharing between Federal and
State authorities would have on efforts to enforce minimum
standards on paid tax return preparers.
SEC. 203. MISDIRECTED TAX REFUND DEPOSITS.
Section 6402 is amended by adding at the end the following new
subsection:
``(n) Misdirected Direct Deposit Refund.--Not later than January 1,
2019, the Secretary shall prescribe regulations to establish procedures
to allow for--
``(1) taxpayers to report instances in which a refund made
by the Secretary by electronic funds transfer was erroneously
delivered to an account at a financial institution for which
the taxpayer is not the owner;
``(2) coordination with financial institutions for the
purpose of--
``(A) identifying erroneous payments described in
paragraph (1); and
``(B) recovery of the erroneously transferred
amounts; and
``(3) the refund to be delivered to the correct account of
the taxpayer.''.
TITLE III--SMALL BUSINESS TAX ADMINISTRATION AND COMPLIANCE
SEC. 301. SAFE HARBOR FOR EMPLOYER TIP REPORTING.
(a) In General.--Subsection (q) of section 3121 is amended--
(1) by striking ``For purposes of this chapter'' and
inserting the following:
``(1) In general.--For purposes of this chapter'', and
(2) by adding at the end the following:
``(2) Tip program safe harbor.--In the case of an employer
for which 1 or more employees receive tips in the course of
their employment which are considered remuneration for such
employment under paragraph (1), the Secretary shall not
initiate a tip examination (as that term is used in the model
Tip Reporting Alternative Commitment agreement promulgated by
the Internal Revenue Service) of the employer (except in
relation to a tip examination of 1 or more employees or former
employees of such employer) if such employer has demonstrated
that it has--
``(A) established an educational program regarding
the applicable laws relating to the proper reporting of
tips received by employees for--
``(i) new employees, which shall include
both verbal explanations and written materials;
and
``(ii) existing employees, which shall be
conducted quarterly;
``(B) established procedures for employees who
receive tips to, in accordance with section 6053(a),
provide monthly reporting of their cash and charged
services and any related tips of $20 or greater;
``(C) complied with any requirements applicable to
employers for purposes of filing returns and collection
and payment of taxes imposed with respect to tips
received by employees; and
``(D) maintained employee records related to--
``(i) contact information for such
employees; and
``(ii) gross receipts from any services
subject to tipping and charge receipts for such
services for a period of not less than 4
calendar years after the calendar year to which
such records relate.''.
(b) Effective Date.--The amendments made by this section shall
apply to tips received for services performed after December 31, 2018.
SEC. 302. INFORMATION REPORTING OF INCOME FROM CERTAIN RENTALS OF SPACE
IN THE BEAUTY SERVICE INDUSTRY.
(a) In General.--Subpart B of part III of subchapter A of chapter
61 is amended by inserting after section 6050Y the following new
section:
``SEC. 6050Z. RETURNS WITH RESPECT TO INCOME FROM CERTAIN RENTALS OF
SPACE FOR BEAUTY SERVICES.
``(a) In General.--Any person who, in connection with its trade or
business or rental activity, receives rental income from 2 or more
individuals providing beauty services in excess of $600 each for a
calendar year for the rental of space to provide such beauty services
to third-party patrons, shall make a return with respect to each such
individual, at such time and in such manner as the Secretary shall
prescribe, which shall include--
``(1) the name, address, and TIN of such individual,
``(2) the total amount received from such individual during
such calendar year, including the date and amount of each
payment, and
``(3) such additional information as the Secretary may
require.
``(b) Statements To Be Furnished to Persons With Respect to Whom
Information Is Required To Be Furnished.--
``(1) In general.--Every person required to make a return
under subsection (a) shall furnish to each individual whose
name is required to be set forth in such return a written
statement showing--
``(A) the name, address, and phone number of the
information contact of the person required to make such
return, and
``(B) the aggregate amount of payments to the
person required to be shown on such return.
``(2) Furnishing of information.--The written statement
required under paragraph (1) shall be furnished to the
individual on or before January 31 of the year following the
calendar year for which the return under subsection (a) was
made.
``(c) Regulations and Guidance.--The Secretary may prescribe such
regulations and other guidance as may be appropriate or necessary to
carry out the purposes of this section, including rules to prevent
duplicative reporting of transactions.
``(d) Beauty Service.--For purposes of this section, the term
`beauty service' means--
``(1) barbering and hair care,
``(2) nail care,
``(3) esthetics, and
``(4) body and spa treatments.''.
(b) Conforming Amendments.--
(1) Section 6724(d)(1)(B) is amended by striking ``or'' at
the end of clause (xxv), by striking ``and'' at the end of
clause (xxvi) and inserting ``or'', and by inserting after
clause (xxvi) the following new clause:
``(xvii) section 6050X(a) (relating to
information reporting with respect to rentals
of space for beauty services), and''.
(2) Paragraph (2) of section 6724(d) is amended--
(A) by striking ``or'' at the end of subparagraph
(II),
(B) by striking the period at the end of the first
subparagraph (JJ) and inserting a comma,
(C) by redesignating the second subparagraph (JJ)
as subparagraph (KK),
(D) in subparagraph (KK), as redesignated by
subparagraph (C), by striking the period at the end and
inserting ``, or'', and
(E) by inserting after subparagraph (KK) the
following new subparagraph:
``(LL) section 6050Z(b)(1) (relating to statements
to providers of beauty services).''.
(3) The table of sections for subpart B of part III of
subchapter A of chapter 61 is amended by adding after the item
relating to section 6050Y the following new item:
``Sec. 6050Z. Returns with respect to income from certain rentals of
space for beauty services.''.
(c) Effective Date.--The amendments made by this section shall
apply to calendar years after 2018.
SEC. 303. RELEASE OF FEDERAL TAX LEVIES WHICH CAUSE BUSINESS HARDSHIP.
(a) In General.--Subparagraph (D) of section 6343(a)(1) is amended
by inserting ``or any trade or business of the taxpayer'' before ``,
or''.
(b) Criteria for Determining Business Hardship.--Subsection (a) of
section 6343 is amended by adding at the end the following new
paragraph:
``(4) Criteria for determining business hardship.--For
purposes of making a determination under paragraph (1)(D), with
respect to a trade or business of the taxpayer, the Secretary
shall take into consideration--
``(A) the economic viability of such trade or
business,
``(B) the nature and extent of the hardship,
including the extent to which the taxpayer exercised
ordinary business care and prudence, and
``(C) any hardships which would be caused to other
individuals or businesses if such trade or business
were liquidated.''.
(c) Effective Date.--The amendments made by this section shall take
effect on the date of the enactment of this Act.
SEC. 304. EXTENSION OF TIME FOR MAKING S CORPORATION ELECTIONS.
(a) In General.--Subsection (b) of section 1362 is amended to read
as follows:
``(b) When Made.--
``(1) In general.--An election under subsection (a) may be
made by a small business corporation for any taxable year not
later than the due date for filing the return of the S
corporation for such taxable year (including extensions).
``(2) Certain elections treated as made for next taxable
year.--If--
``(A) an election under subsection (a) is made for
any taxable year within the period described in
paragraph (1), but
``(B) either--
``(i) on 1 or more days in such taxable
year and before the day on which the election
was made the corporation did not meet the
requirements of subsection (b) of section 1361,
or
``(ii) 1 or more of the persons who held
stock in the corporation during such taxable
year and before the election was made did not
consent to the election,
then such election shall be treated as made for the
following taxable year.
``(3) Authority to treat late elections, etc., as timely.--
If--
``(A) an election under subsection (a) is made for
any taxable year after the date prescribed by this
subsection for making such election for such taxable
year or no such election is made for any taxable year,
and
``(B) the Secretary determines that there was
reasonable cause for the failure to timely make such
election,
the Secretary may treat such an election as timely made for
such taxable year.
``(4) Election on timely filed returns.--Except as
otherwise provided by the Secretary, an election under
subsection (a) for any taxable year may be made on a timely
filed return of the S corporation for such taxable year.
``(5) Secretarial authority.--The Secretary may prescribe
such regulations, rules, or other guidance as may be necessary
or appropriate for purposes of applying this subsection.''.
(b) Coordination With Certain Other Provisions.--
(1) Qualified subchapter s subsidiaries.--Section
1361(b)(3)(B) is amended by adding at the end the following
flush sentence:
``Rules similar to the rules of section 1362(b) shall
apply with respect to any election under clause
(ii).''.
(2) Qualified subchapter s trusts.--Section 1361(d)(2) is
amended by striking subparagraph (D).
(c) Revocations.--Paragraph (1) of section 1362(d) is amended--
(1) by striking ``subparagraph (D)'' in subparagraph (C)
and inserting ``subparagraphs (D) and (E)'', and
(2) by adding at the end the following new subparagraph:
``(E) Authority to treat late revocations as
timely.--If--
``(i) a revocation under subparagraph (A)
is made for any taxable year after the date
prescribed by this paragraph for making such
revocation for such taxable year or no such
revocation is made for any taxable year, and
``(ii) the Secretary determines that there
was reasonable cause for the failure to timely
make such revocation,
the Secretary may treat such a revocation as timely
made for such taxable year.''.
(d) Effective Date.--
(1) In general.--Except as otherwise provided in this
subsection, the amendments made by this section shall apply to
elections for taxable years beginning after December 31, 2018.
(2) Revocations.--The amendments made by subsection (c)
shall apply to revocations after December 31, 2018.
SEC. 305. QUARTERLY REPORTING OF ESTIMATED TAX PAYMENTS.
(a) In General.--The table contained in paragraph (2) of section
6654(c) is amended--
(1) by striking ``June 15'' and inserting ``July 15'', and
(2) by striking ``September 15'' and inserting ``October
15''.
(b) Effective Date.--The amendments made by this section shall
apply to installments due in taxable years beginning after December 31,
2018.
TITLE IV--RETIREMENT PLANS AND SAVINGS
SEC. 401. EXPANSION OF EMPLOYEE PLANS COMPLIANCE RESOLUTION SYSTEM.
(a) In General.--Except as otherwise provided in regulations
prescribed by the Secretary of the Treasury or the Secretary's delegate
(referred to in this section as the ``Secretary''), any inadvertent
failure to comply with the rules applicable under section 401(a),
403(a), 403(b), 408(p), or 408(k) of the Internal Revenue Code of 1986
may be self-corrected under the Employee Plans Compliance Resolution
System (as described in Revenue Procedure 2016-51 or any successor
guidance), except to the extent that such failure was identified by
Secretary prior to any actions that demonstrate a commitment to
implement a self-correction.
(b) Loan Error.--The Secretary of Labor shall treat any loan error
corrected pursuant to subsection (a) as meeting the requirements of the
Voluntary Fiduciary Correction Program of the Department of Labor.
(c) EPCRS for IRAs.--The Secretary shall expand the Employee Plans
Compliance Resolution System to allow custodians of individual
retirement plans to address inadvertent errors for which the owner of
an individual retirement plan was not at fault, including (but not
limited to)--
(1) waivers of the excise tax that would otherwise apply
under section 4974 of the Internal Revenue Code of 1986;
(2) under the self-correction component of the Employee
Plans Compliance Resolution System, waivers of the 60-day
deadline for a rollover where the deadline is missed for
reasons beyond the reasonable control of the account owner; and
(3) rules permitting a nonspouse beneficiary to return
distributions to an inherited individual retirement plan
described in section 408(d)(3)(C) of the Internal Revenue Code
of 1986 in a case where, due to an inadvertent error by a
service provider, the beneficiary had reason to believe that
the distribution could be rolled over without inclusion in
income of any part of the distributed amount.
(d) Required Minimum Distribution Corrections.--The Secretary shall
expand the Employee Plans Compliance Resolution System to allow plans
to which such system applies and custodians of individual retirement
plans to self-correct, without an excise tax, any inadvertent errors
pursuant to which a distribution is made no more than 180 days after it
was required to be made.
(e) Additional Safe Harbors.--The Secretary shall expand the
Employee Plans Compliance Resolution System (as described in Revenue
Procedure 2016-51 or any successor guidance) to provide additional safe
harbor means of correcting inadvertent failures described in subsection
(a), including safe harbor means of calculating the earnings that must
be restored to a plan in cases where plan assets have been depleted by
reason of an inadvertent failure.
TITLE V--ASSISTANCE FOR LOW-INCOME TAXPAYERS
SEC. 501. ESTABLISHMENT OF INCOME THRESHOLD FOR REFERRAL TO PRIVATE
DEBT COLLECTION.
(a) In General.--Section 6306(d)(3) is amended by striking ``or''
at the end of subparagraph (C), by adding ``or'' at the end of
subparagraph (D), and by inserting after subparagraph (D) the following
new subparagraph:
``(E) in the case of a tax receivable which is
identified by the Secretary (or the Secretary's
delegate) during the period beginning on the date which
is 180 days after the date of the enactment of this Act
and ending on December 31, 2019, a taxpayer who is an
individual with adjusted gross income, as determined
for the most recent taxable year for which such
information is available, which does not exceed 250
percent of the applicable poverty level (as determined
by the Secretary),''.
(b) Effective Date.--The amendments made by this section shall
apply to tax receivables identified by the Secretary of the Treasury
(or the Secretary's delegate) after the date which is 180 days after
the date of the enactment of this Act.
SEC. 502. RETURN PREPARATION PROGRAMS FOR APPLICABLE TAXPAYERS.
(a) In General.--Chapter 77 is amended by inserting after section
7526 the following new section:
``SEC. 7526A. RETURN PREPARATION PROGRAMS FOR APPLICABLE TAXPAYERS.
``(a) Establishment of Volunteer Income Tax Assistance Matching
Grant Program.--The Secretary shall establish a Community Volunteer
Income Tax Assistance Matching Grant Program under which the Secretary
may, subject to the availability of appropriated funds, make grants to
provide matching funds for the development, expansion, or continuation
of qualified return preparation programs assisting applicable taxpayers
and members of underserved populations.
``(b) Use of Funds.--
``(1) In general.--Qualified return preparation programs
may use grants received under this section for--
``(A) ordinary and necessary costs associated with
program operation in accordance with cost principles
under the applicable Office of Management and Budget
circular, including--
``(i) wages or salaries of persons
coordinating the activities of the program,
``(ii) developing training materials,
conducting training, and performing quality
reviews of the returns prepared under the
program,
``(iii) equipment purchases, and
``(iv) vehicle-related expenses associated
with remote or rural tax preparation services,
``(B) outreach and educational activities described
in subsection (c)(2)(B), and
``(C) services related to financial education and
capability, asset development, and the establishment of
savings accounts in connection with tax return
preparation.
``(2) Requirement of matching funds.--A qualified return
preparation program must provide matching funds on a dollar-
for-dollar basis for all grants provided under this section.
Matching funds may include--
``(A) the salary (including fringe benefits) of
individuals performing services for the program,
``(B) the cost of equipment used in the program,
and
``(C) other ordinary and necessary costs associated
with the program.
Indirect expenses, including general overhead of any entity
administering the program, shall not be counted as matching
funds.
``(c) Application.--
``(1) In general.--Each applicant for a grant under this
section shall submit an application to the Secretary at such
time, in such manner, and containing such information as the
Secretary may reasonably require.
``(2) Priority.--In awarding grants under this section, the
Secretary shall give priority to applications which
demonstrate--
``(A) assistance to applicable taxpayers, with
emphasis on outreach to, and services for, such
taxpayers,
``(B) taxpayer outreach and educational activities
relating to eligibility and availability of income
supports available through this title, including the
earned income tax credit, and
``(C) specific outreach and focus on one or more
underserved populations.
``(3) Amounts taken into account.--In determining matching
grants under this section, the Secretary shall only take into
account amounts provided by the qualified return preparation
program for expenses described in subsection (b).
``(d) Program Adherence.--
``(1) In general.--The Secretary shall establish procedures
for, and shall conduct not less frequently than once every 5
calendar years during which a qualified return preparation
program is operating under a grant under this section, periodic
site visits--
``(A) to ensure the program is carrying out the
purposes of this section, and
``(B) to determine whether the program meets such
program adherence standards as the Secretary shall by
regulation or other guidance prescribe.
``(2) Additional requirements for grant recipients not
meeting program adherence standards.--In the case of any
qualified return preparation program which--
``(A) is awarded a grant under this section, and
``(B) is subsequently determined--
``(i) not to meet the program adherence
standards described in paragraph (1)(B), or
``(ii) not to be otherwise carrying out the
purposes of this section,
such program shall not be eligible for any additional grants
under this section unless such program provides sufficient
documentation of corrective measures established to address any
such deficiencies determined.
``(e) Definitions.--For purposes of this section--
``(1) Qualified return preparation program.--The term
`qualified return preparation program' means any program--
``(A) which provides assistance to individuals, not
less than 90 percent of whom are applicable taxpayers,
in preparing and filing Federal income tax returns,
``(B) which is administered by a qualified entity,
``(C) in which all volunteers who assist in the
preparation of Federal income tax returns meet the
training requirements prescribed by the Secretary, and
``(D) which uses a quality review process which
reviews 100 percent of all returns.
``(2) Qualified entity.--
``(A) In general.--The term `qualified entity'
means any entity which--
``(i) is an eligible organization,
``(ii) is in compliance with Federal tax
filing and payment requirements,
``(iii) is not debarred or suspended from
Federal contracts, grants, or cooperative
agreements, and
``(iv) agrees to provide documentation to
substantiate any matching funds provided
pursuant to the grant program under this
section.
``(B) Eligible organization.--The term `eligible
organization' means--
``(i) an institution of higher education
which is described in section 102 (other than
subsection (a)(1)(C) thereof) of the Higher
Education Act of 1965 (20 U.S.C. 1002), as in
effect on the date of the enactment of this
section, and which has not been disqualified
from participating in a program under title IV
of such Act,
``(ii) an organization described in section
501(c) and exempt from tax under section
501(a),
``(iii) a local government agency,
including--
``(I) a county or municipal
government agency, and
``(II) an Indian tribe, as defined
in section 4(13) of the Native American
Housing Assistance and Self-
Determination Act of 1996 (25 U.S.C.
4103(13)), including any tribally
designated housing entity (as defined
in section 4(22) of such Act (25 U.S.C.
4103(22))), tribal subsidiary,
subdivision, or other wholly owned
tribal entity,
``(iv) a local, State, regional, or
national coalition (with one lead organization
which meets the eligibility requirements of
clause (i), (ii), or (iii) acting as the
applicant organization), or
``(v) in the case of applicable taxpayers
and members of underserved populations with
respect to which no organizations described in
the preceding clauses are available--
``(I) a State government agency, or
``(II) an office providing
Cooperative Extension services (as
established at the land-grant colleges
and universities under the Smith-Lever
Act of May 8, 1914).
``(3) Applicable taxpayers.--The term `applicable taxpayer'
means a taxpayer whose income for the taxable year does not
exceed an amount equal to the completed phaseout amount under
section 32(b) for a married couple filing a joint return with 3
or more qualifying children, as determined in a revenue
procedure or other published guidance.
``(4) Underserved population.--The term `underserved
population' includes populations of persons with disabilities,
persons with limited English proficiency, Native Americans,
individuals living in rural areas, members of the Armed Forces
and their spouses, and the elderly.
``(f) Special Rules and Limitations.--
``(1) Duration of grants.--Upon application of a qualified
return preparation program, the Secretary is authorized to
award a multi-year grant not to exceed 3 years.
``(2) Aggregate limitation.--Unless otherwise provided by
specific appropriation, the Secretary shall not allocate more
than $30,000,000 per fiscal year (exclusive of costs of
administering the program) to grants under this section.
``(g) Promotion of Programs.--
``(1) In general.--The Secretary shall promote tax
preparation through qualified return preparation programs
through the use of mass communications and other means.
``(2) Provision of information regarding qualified return
preparation programs.--The Secretary may provide taxpayers
information regarding qualified return preparation programs
receiving grants under this section.
``(3) VITA grantee referral.--Qualified return preparation
programs receiving a grant under this section are encouraged,
in appropriate cases, to--
``(A) advise taxpayers of the availability of, and
eligibility requirements for receiving, advice and
assistance from qualified low-income taxpayer clinics
receiving funding under section 7526, and
``(B) provide information regarding the location
of, and contact information for, such clinics.''.
(b) Clerical Amendment.--The table of sections for chapter 77 is
amended by inserting after the item relating to section 7526 the
following new item:
``Sec. 7526A. Return preparation programs for applicable taxpayers.''.
SEC. 503. LOW-INCOME TAXPAYER CLINICS.
(a) Promotion of Clinics.--Section 7526 is amended by adding at the
end the following new subsection:
``(d) Promotion of Clinics.--The Secretary is authorized to promote
the benefits of and encourage the use of qualified low-income taxpayer
clinics through the use of mass communications, referrals, and other
means.''.
(b) IRS Referrals to Clinics.--Subsection (c) of section 7526 is
amended by adding at the end the following new paragraph:
``(6) IRS referrals.--Notwithstanding any other provision
of law, the Secretary may refer taxpayers to specific qualified
low-income taxpayer clinics receiving funding under this
section.''.
(c) Effective Date.--The amendments made by this section shall take
effect on the date of the enactment of this Act.
SEC. 504. LOW-INCOME EXCEPTION FOR PAYMENTS OTHERWISE REQUIRED IN
CONNECTION WITH A SUBMISSION OF AN OFFER-IN-COMPROMISE.
(a) In General.--Section 7122(c) is amended by adding at the end
the following new paragraph:
``(3) Exception for low-income taxpayers.--Paragraph (1),
and any user fee otherwise required in connection with the
submission of an offer-in-compromise, shall not apply to any
offer-in-compromise with respect to a taxpayer who is an
individual with adjusted gross income, as determined for the
most recent taxable year for which such information is
available, which does not exceed 250 percent of the applicable
poverty level (as determined by the Secretary).''.
(b) Effective Date.--The amendment made by this section shall apply
to offers-in-compromise submitted after the date of the enactment of
this Act.
TITLE VI--APPEALS PROCESS
SEC. 601. RIGHT TO INDEPENDENT CONFERENCE.
(a) In General.--Section 1001 of the Internal Revenue Service
Restructuring and Reform Act of 1998 is amended by redesignating
subsection (c) as subsection (d) and by inserting after subsection (b)
the following new subsection:
``(c) Right to Independent Conference.--Under the organization plan
of the Internal Revenue Service, a taxpayer shall have the right to a
conference with the Internal Revenue Service Office of Appeals which
does not include personnel from the Office of Chief Counsel for the
Internal Revenue Service or the compliance functions of the Internal
Revenue Service unless the taxpayer specifically consents to the
participation of such personnel.''.
(b) Effective Date.--This section shall apply to conferences
occurring after the date of the enactment of this Act.
SEC. 602. ACCESS TO CASE FILES.
(a) In General.--In the case of any specified taxpayer with respect
to which a conference with the Internal Revenue Service Office of
Appeals has been scheduled, the taxpayer shall be provided access to
the nonprivileged portions of the case file on record regarding the
disputed issues (other than documents provided by the taxpayer to the
Internal Revenue Service) not later than 10 days before the date of
such conference.
(b) Taxpayer Election To Expedite Conference.--If the taxpayer so
elects, subsection (a) shall be applied by substituting ``the date of
such conference'' for ``10 days before the date of such conference''.
(c) Specified Taxpayer.--For purposes of this section:
(1) In general.--The term ``specified taxpayer'' means--
(A) in the case of any taxpayer who is a natural
person, a taxpayer whose adjusted gross income does not
exceed $400,000, and
(B) in the case of any other taxpayer, a taxpayer
whose gross receipts do not exceed $5,000,000.
(2) Aggregation rule.--Rules similar to the rules of
section 448(c)(2) of the Internal Revenue Code of 1986 shall
apply for purposes of paragraph (1)(B).
(d) Effective Date.--This section shall apply to conferences
occurring after the date which is 1 year after the date of the
enactment of this Act.
SEC. 603. ENSURING TAXPAYER RIGHT TO APPEAL.
(a) In General.--Subsection (a) of section 6212 is amended--
(1) by striking ``In General.--If the Secretary'' and
inserting ``In General.--
``(1) Authorization.--If--
``(A) the Secretary'',
(2) by striking ``44, he is authorized'' and inserting
``44, and
``(B) the requirements of paragraph (2) have been
met with respect to such deficiency,
the Secretary is authorized'', and
(3) by adding at the end the following new paragraph:
``(2) Opportunity for administrative review in the office
of appeals.--
``(A) In general.--The requirements of this
paragraph are met with respect to a deficiency if,
prior to the issuance of the notice of deficiency under
paragraph (1)--
``(i) the taxpayer has been issued a letter
of proposed deficiency that explains the basis
for the determination of deficiency and allows
the taxpayer an opportunity for administrative
review in the Internal Revenue Service Office
of Appeals, and
``(ii) either--
``(I) the time provided in such
letter for contacting the Office of
Appeals has expired and the taxpayer
has not so contacted such Office, or
``(II) the Office of Appeals has
issued a decision with respect to such
deficiency.
``(B) Frivolous tax positions.--The Secretary is
authorized to issue regulations limiting the
application of subparagraph (A) in cases involving
solely the failure or refusal to comply with the tax
laws because of moral, religious, political,
constitutional, conscientious, or similar grounds, or
for other positions listed as frivolous under section
6702(c).
``(C) Cases designated for litigation.--
Subparagraph (A) shall not apply in the case of issues
designated for litigation in accordance with section
7124.''.
(b) Opportunity for Appeal if Fewer Than 60 Days Remain on Statute
of Limitations.--Section 6212 is amended by adding at the end the
following new subsection:
``(e) Opportunity for Appeal if Fewer Than 60 Days Remain on
Statute of Limitations.--In the case of any issues relating to a
potential deficiency with respect to which 60 days or fewer remain in
the period applicable under section 6501, if the taxpayer agrees to the
extension of such period by 12 months, the Secretary shall issue a
letter of proposed deficiency described in subsection (a)(2)(A)(i)
allowing the taxpayer an opportunity for administrative review of such
issues in the Internal Revenue Service Office of Appeals before a
notice of deficiency is issued under this section. Rules similar to the
rules of subsection (a)(2)(B) shall apply for purposes of this
subsection.''.
(c) Effective Date.--The amendments made by this section shall
apply to notices of deficiency issued after the date of the enactment
of this Act.
SEC. 604. LIMITATION ON DESIGNATION OF CASES AS NOT ELIGIBLE FOR
REFERRAL TO INDEPENDENT OFFICE OF APPEALS.
(a) In General.--If any taxpayer which is in receipt of notice of
deficiency authorized under section 6212 of the Internal Revenue Code
of 1986 requests referral to the Internal Revenue Service Office of
Appeals and such request is denied, the Commissioner of Internal
Revenue shall provide such taxpayer a written notice which--
(1) provides a detailed description of the facts involved,
the basis for the decision to deny the request, and a detailed
explanation of how the basis of such decision applies to such
facts, and
(2) describes the procedures proscribed under subsection
(c) for protesting the decision to deny the request.
(b) Report to Congress.--The Commissioner of Internal Revenue shall
submit a written report to Congress on an annual basis which includes
the number of requests described in subsection (a) which were denied
and the reasons (described by category) that such requests were denied.
(c) Procedures for Protesting Denial of Request.--The Commissioner
of Internal Revenue shall prescribe procedures for protesting to the
Commissioner of Internal Revenue (personally and not through any
delegate) a denial of a request described in subsection (a).
(d) Not Applicable to Frivolous Positions.--This section shall not
apply to a request for referral to the Internal Revenue Service Office
of Appeals which is denied on the basis that the issue involved is a
frivolous position (within the meaning of section 6702(c) of the
Internal Revenue Code of 1986).
SEC. 605. PROCEDURES RELATED TO SECRETARIAL AUTHORITY TO DESIGNATE
CASES FOR LITIGATION.
(a) In General.--Chapter 74 is amended by redesignating section
7124 as section 7125 and by inserting after section 7123 the following
new section:
``SEC. 7124. PROCEDURES RELATED TO SECRETARIAL AUTHORITY TO DESIGNATE
CASES FOR LITIGATION.
``(a) In General.--For any matter which the Commissioner of
Internal Revenue and the Chief Counsel for the Internal Revenue Service
have determined shall be designated for litigation, such determination
shall be--
``(1) based on a joint written recommendation by the
Commissioner of the relevant operating division of the Internal
Revenue Service and the Division Counsel for such operating
division, which shall include an explanation as to why the
designation is preferable to other means of resolving the
matter, and
``(2) made in consultation with the Associate Chief Counsel
with relevant subject matter jurisdiction over such matter.
``(b) Notification Prior to Recommendation.--Prior to submission of
a recommendation described in subsection (a)(1), the Division Counsel
for the relevant operating division of the Internal Revenue Service
shall provide written notification to the taxpayer regarding the
recommendation, including--
``(1) a description of the issues recommended for
designation and the reasons for such recommendation, and
``(2) notification that the taxpayer's views may be
presented in writing or in person to the Division Counsel and
the Commissioner of the relevant operating division--
``(A) within 60 days of such notification, or
``(B) prior to such other date as the taxpayer and
the Division Counsel may agree.
``(c) Notification After Recommendation.--Not later than 30 days
after submission of a recommendation described in subsection (a)(1),
the Division Counsel for the relevant operating division of the
Internal Revenue Service shall provide written notification to the
taxpayer regarding submission of the recommendation, including
notification that the taxpayer's views may be presented in writing or
in person to the Commissioner of Internal Revenue and the Chief Counsel
for the Internal Revenue Service--
``(1) within 60 days of such notification, or
``(2) prior to such other date as the taxpayer, the
Commissioner of Internal Revenue, and the Chief Counsel for the
Internal Revenue Service may agree.
``(d) Notice of Approval of Designation.--For any matter which the
Commissioner of Internal Revenue and the Chief Counsel for the Internal
Revenue Service have determined shall be designated for litigation--
``(1) the Division Counsel for the relevant operating
division of the Internal Revenue Service shall provide written
notification to the taxpayer regarding such determination, and
``(2) the jurisdiction of the Internal Revenue Service
Office of Appeals over such matter shall be limited solely to
any issues not included in such designation.
``(e) Rescinding of Designation.--The Chief Counsel for the
Internal Revenue Service may rescind any designation of a matter for
litigation if the Chief Counsel determines that continuation of such
litigation does not serve the purpose for which such designation was
originally made.''.
(b) Clerical Amendment.--The table of sections for chapter 74 is
amended by striking the item relating to section 7124 and inserting the
following new items:
``Sec. 7124. Procedures related to Secretarial authority to designate
cases for litigation.
``Sec. 7125. Cross references.''.
(c) Effective Date.--The amendments made by this section shall
apply to the designation of issues for litigation occurring after the
date of the enactment of this Act.
TITLE VII--MISCELLANEOUS
SEC. 701. MODIFICATION OF AUTHORITY TO ISSUE DESIGNATED SUMMONS.
(a) In General.--Paragraph (1) of section 6503(j) is amended by
striking ``coordinated examination program'' and inserting
``coordinated industry case program''.
(b) Designated Summons.--Clause (i) of section 6503(j)(2)(A) is
amended to read as follows:
``(i) the issuance of such summons is
preceded by a review and written approval of
such issuance by the Large Business and
International Division Commissioner and the
Division Counsel of the Office of Chief Counsel
(or their successors)--
``(I) which clearly establishes
that the taxpayer did not reasonably
cooperate with reasonable requests by
the Secretary for witnesses, documents,
meetings, and interviews, and
``(II) which is attached to such
summons,''.
(c) Burden of Proof.--Subsection (j) of section 6503 is amended by
adding at the end the following new paragraph:
``(4) Burden of proof.--In any court proceeding described
in paragraph (3), the Secretary shall bear the burden of
proving that the corporation described in paragraph (1) did not
reasonably cooperate with reasonable requests by the Secretary
for witnesses, documents, meetings, and interviews.''.
(d) Effective Date.--The amendments made by this section shall
apply to summonses issued after the date of the enactment of this Act.
SEC. 702. STREAMLINED CRITICAL PAY AUTHORITY FOR INFORMATION TECHNOLOGY
POSITIONS.
(a) Authority.--Section 9503(a) of title 5, United States Code, is
amended--
(1) in the matter preceding paragraph (1), by striking
``the Secretary of the Treasury'' and all that follows through
``establish'' and inserting ``the Secretary of the Treasury
may, during the period beginning on October 1, 2018, and ending
on September 30, 2023, establish'', and
(2) in paragraph (1)(B), by striking ``the Internal Revenue
Service's successful accomplishment of an important mission''
and inserting ``the functionality of the information technology
operations of the Internal Revenue Service''.
(b) Recruitment, Retention, Relocation Incentives, and Relocation
Expenses.--Section 9504 of title 5, United States Code, is amended--
(1) in subsection (a)--
(A) by striking ``Before September 30, 2013'' and
inserting ``During the period beginning on October 1,
2018, and ending on September 30, 2023'', and
(B) by inserting ``for employees holding positions
described in section 9503(a)(1)'' after ``incentives'',
and
(2) in subsection (b)--
(A) by striking ``Before September 30, 2013'' and
inserting ``During the period beginning on October 1,
2018, and ending on September 30, 2023'',
(B) by striking ``employees transferred or
reemployed'' and inserting ``employees holding
positions described in section 9503(a)(1) who are
transferred or reemployed during such period'', and
(C) by striking ``section 9502 or 9503 after June
1, 1998'' and inserting ``section 9503 during such
period''.
(c) Performance Awards for Senior Executives.--Section 9505(a) of
title 5, United States Code, is amended--
(1) by striking ``Before September 30, 2013'' and inserting
``During the period beginning on October 1, 2018, and ending on
September 30, 2023'', and
(2) by striking ``significant functions'' and inserting
``the information technology operations''.
(d) Effective Date.--The amendments made by this section shall
apply to payments made on or after the date of the enactment of this
Act.
SEC. 703. UNIFORM STANDARDS FOR THE USE OF ELECTRONIC SIGNATURES FOR
DISCLOSURE AUTHORIZATIONS TO, AND OTHER AUTHORIZATIONS
OF, PRACTITIONERS.
Paragraph (3) of section 6061(b) is amended to read as follows:
``(3) Published guidance.--
``(A) In general.--The Secretary shall publish
guidance as appropriate to define and implement any
waiver of the signature requirements or any method
adopted under paragraph (1).
``(B) Electronic signatures for disclosure
authorizations to, and other authorizations of,
practitioners.--Not later than 6 months after the date
of the enactment of this subparagraph, the Secretary
shall publish guidance to establish uniform standards
and procedures for the acceptance of taxpayers'
signatures appearing in commercially provided
electronic form with respect to any request for
disclosure of a taxpayer's return or return information
under section 6103(c) to a practitioner or any power of
attorney granted by a taxpayer to a practitioner.
``(C) Practitioner.--For purposes of subparagraph
(B), the term `practitioner' means any individual in
good standing who is regulated under section 330 of
title 31, United States Code.''.
SEC. 704. LIMITATION ON ACCESS OF NON-INTERNAL REVENUE SERVICE
EMPLOYEES TO RETURNS AND RETURN INFORMATION.
(a) In General.--Section 7602 is amended by adding at the end the
following new subsection:
``(f) Limitation on Access of Persons Other Than Internal Revenue
Service Officers and Employees.--The Secretary shall not, under the
authority of section 6103(n), provide any books, papers, records, or
other data obtained pursuant to this section to any person authorized
under section 6103(n), except when such person requires such
information for the sole purpose of providing expert evaluation and
assistance to the Internal Revenue Service. No person other than an
officer or employee of the Internal Revenue Service or the Office of
Chief Counsel may, on behalf of the Secretary, question a witness under
oath whose testimony was obtained pursuant to this section.''.
(b) Effective Date.--
(1) In general.--Except as provided in paragraph (2), the
amendment made by this section shall take effect on the date of
the enactment of this Act.
(2) Application to contracts in effect.--The amendment made
by this section shall apply to any contract in effect under
section 6103(n) of the Internal Revenue Code of 1986, pursuant
to temporary Treasury Regulation section 301.7602-1T proposed
in Internal Revenue Bulletin 2014-28, Treasury Regulation
section 301.7602-1(b)(3), or any similar or successor
regulation, that is in effect on the date of the enactment of
this Act.
<all>
Introduced in Senate
Introduced in Senate
Read twice and referred to the Committee on Finance.
Committee on Small Business and Entrepreneurship. Hearings held. Hearings printed: S.Hrg. 115-574.
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