I'll give you the short version of this bill.
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Amends 26 U.S.C. §7213 by replacing the $5,000 maximum fines in paragraphs (1)–(4) with $10,000 and by adding a new paragraph (6) that provides an inflation adjustment for the new $10,000 amounts for calendar years after 2025, calculated using the cost-of-living adjustment under section 1(f)(3) with specified substitutions.
Amends subsection (a) by replacing paragraph (1) and adding a new paragraph (2) that limits the application of paragraph (1) to property used as the taxpayer's principal residence unless the Secretary of the Treasury makes a written determination that (i) all other property, if sold, is insufficient to pay the tax or discharge the liability, and (ii) such action will not create an economic hardship for the taxpayer; also restricts delegation of that written-determination authority to the Commissioner of Internal Revenue or a district director or assistant district director of the Internal Revenue Service.
Adds new section 7531 to Chapter 77 of Title 26 establishing a prohibition on the Internal Revenue Service Independent Office of Appeals considering or deciding any issue not within the scope of the initial determination and specifying categories of matters deemed outside that scope.
Amends the table of sections for Chapter 77 by adding an item for the newly created section.
Adds a new subsection (d) to 26 U.S.C. § 7123 establishing availability rules for mediation and arbitration, requirements for publicizing exclusions, provisions allowing independent mediators and cost-sharing rules (with an exception for certain low-income individuals and small businesses), and timing for when taxpayers may elect dispute resolution.
Amends 26 U.S.C. §7803 by inserting new language after subsection (d)(1)(E) to require reporting to TIGTA concerning terminations or mitigation actions related to prohibited ex parte communications described in this section.
Amends 26 U.S.C. 7431 by (1) increasing the statutory per-act damages amount in subsection (c)(1)(A) to $10,000 and adding an automatic cost-of-living adjustment for calendar years after 2025, and (2) extending the period for bringing an action under subsection (d) from 2 years to 5 years.
Modifies 26 U.S.C. 7214 by replacing numeric penalty amounts in subsections (a) and (b) (as reflected in this section's text), redesignating existing subsection (c) as subsection (d), and inserting a new subsection (c) that provides annual inflation adjustments (cost-of-living increases) to the dollar amounts in subsections (a) and (b) for calendar years after 2025, with a specified substitution in the section 1(f)(3) COLA determination.
Amends 26 U.S.C. §7433 to (1) increase the monetary caps in subsection (b) from $1,000,000/$100,000 to $5,000,000/$500,000, (2) add an inflation-adjustment subsection applying to calendar years after 2025, and (3) extend the limitations period in subsection (d)(3) from 2 years to 5 years.
Amends 26 U.S.C. 7430(c) by adding a clause exempting 'eligible small business' from the net worth limitation in subparagraph (D)(ii) and by adding a new subparagraph (F) that defines 'eligible small business' and provides an inflation adjustment to the $50,000,000 threshold.
And 9 more affected sections...
This bill strengthens taxpayer protections and changes how the IRS conducts audits, appeals, collections, and employee discipline. It narrows what the Independent Office of Appeals may consider, expands taxpayer options for conference, mediation, and arbitration, limits certain enforcement actions against primary residences, and requires additional oversight of IRS selection criteria for audits.
The bill also raises civil-damage and penalty caps for unauthorized disclosures and misconduct, adjusts time limits for suits, creates a modest deduction for certain National Research Program audit expenses, sets a 10-year term for the National Taxpayer Advocate, and changes rules for offers-in-compromise, levy releases, and IRS disciplinary procedures — all intended to increase taxpayer protections, oversight, and accountability while imposing new constraints and liability risks on the IRS and its staff.
Referred to the Committee on Ways and Means, and in addition to the Committee on Oversight and Government Reform, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.
Introduced April 9, 2025 by David Kustoff · Last progress April 9, 2025