Sponsor
John Cornyn
Senator · R-TX
Senator · R-TX
The bill strengthens taxpayer protections, privacy, fairness in appeals, and remedies for IRS misconduct but does so by adding procedural constraints and higher liability that may slow collections, increase IRS administrative and litigation costs, and concentrate certain personnel authorities.
Taxpayers will get more impartial, accessible appeals and alternative dispute resolution options because the bill bars ex parte contacts, guarantees independent conferences, expands mediation/arbitration availability, and requires transparency about categorical exclusions.
Taxpayers' privacy and financial safety are strengthened because statutory damages for unauthorized disclosures and maximum fines for willful disclosures are raised (with inflation indexing), increasing deterrence against improper release of return information.
Taxpayers — especially members of protected classes — will face less politically motivated targeting because the bill bars ideology-based screening, requires TIGTA reviews, and mandates semiannual reporting on discriminatory selection criteria.
Taxpayers may be barred from having new, legitimate legal theories considered on appeal because Appeals would generally be limited to issues raised in the original examination, which could force more cases into court and increase litigation costs.
Expanding statutory damages, longer limitations, and higher caps for unauthorized collection or disclosure increase potential fiscal liability for the Treasury and could drive higher litigation and defense costs funded by taxpayers.
Restricting the IRS's ability to seize principal residences and requiring senior-official signoffs could delay collections, reduce near‑term revenue, and shift enforcement costs onto other taxpayers while increasing administrative burden.
Based on analysis of 32 sections of legislative text.
Reforms IRS appeals and enforcement rules, strengthens taxpayer protections and oversight, raises penalties for improper IRS actions, and adds a limited NRP audit defense deduction.
Official title: Provide a taxpayer bill of rights for small businesses.
Introduced April 9, 2025 by John Cornyn · Last progress April 9, 2025
Reforms how the IRS and its Independent Office of Appeals handle disputes and taxpayer information, strengthens procedural protections for taxpayers, raises civil and criminal penalties for improper collection and disclosures, and changes IRS personnel and disciplinary rules. It also creates a limited above-the-line deduction for defense costs in certain IRS National Research Program audits, expands alternative dispute resolution options, and adjusts rules for offers‑in‑compromise and recovery of litigation/administrative fees for small businesses.