Protect Innocent Victims of Taxation After Fire Extension Act

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[S. 3372 Introduced in Senate (IS)]

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119th CONGRESS
  1st Session
                                S. 3372

    To amend the Internal Revenue Code of 1986 to exclude qualified 
  wildfire relief payments from gross income, and for other purposes.


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                   IN THE SENATE OF THE UNITED STATES

                            December 4, 2025

   Mr. Padilla (for himself, Ms. Lummis, Mr. Wyden, and Mr. Sheehy) 
introduced the following bill; which was read twice and referred to the 
                          Committee on Finance

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                                 A BILL


 
    To amend the Internal Revenue Code of 1986 to exclude qualified 
  wildfire relief payments from gross income, and for other purposes.

    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Protect Innocent Victims of Taxation 
After Fire Extension Act''.

SEC. 2. EXCLUSION FROM GROSS INCOME FOR COMPENSATION FOR LOSSES OR 
              DAMAGES RESULTING FROM WILDFIRES.

    (a) In General.--Part III of subchapter B of chapter 1 of the 
Internal Revenue Code of 1986 is amended by inserting after section 
139L the following new section:

``SEC. 139M. COMPENSATION FOR LOSSES OR DAMAGES RESULTING FROM 
              WILDFIRES.

    ``(a) In General.--Gross income shall not include any amount 
received by an individual as a qualified wildfire relief payment.
    ``(b) Qualified Wildfire Relief Payment.--For purposes of this 
section--
            ``(1) In general.--The term `qualified wildfire relief 
        payment' means any amount received by or on behalf of an 
        individual as compensation for losses, expenses, or damages 
        (including compensation for additional living expenses, lost 
        wages (other than compensation for lost wages paid by the 
        employer which would have otherwise paid such wages), personal 
        injury, death, or emotional distress) incurred as a result of a 
        qualified wildfire disaster, but only to the extent the losses, 
        expenses, or damages compensated by such payment are not 
        compensated for by insurance or otherwise.
            ``(2) Qualified wildfire disaster.--The term `qualified 
        wildfire disaster' means any federally declared disaster (as 
        defined in section 165(i)(5)(A)) declared, after December 31, 
        2014, as a result of any forest or range fire.
    ``(c) Denial of Double Benefit.--Notwithstanding any other 
provision of this subtitle--
            ``(1) no deduction or credit shall be allowed (to the 
        individual for whose benefit a qualified wildfire relief 
        payment is made) for, or by reason of, any expenditure to the 
        extent of the amount excluded under this section with respect 
        to such expenditure, and
            ``(2) no increase in the basis or adjusted basis of any 
        property shall result from any amount excluded under this 
        section with respect to such property.''.
    (b) Clerical Amendment.--The table of sections for part III of 
subchapter B of chapter 1 of such Code is amended by inserting after 
the item relating to section 139L the following new item:

``Sec. 139M. Compensation for losses or damages resulting from 
                            wildfires.''.
    (c) Effective Date.--The amendments made by this section shall 
apply to amounts received after December 31, 2025.
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