Sponsors (2)
The bill gives taxpayers clearer, expedited ways to correct and reopen Tax Court judgments and preserves fraud remedies, but enforces a strict one-year deadline, does not halt collections during relief efforts, and may increase litigation and procedural hurdles and costs.
Taxpayers can seek relief to reopen Tax Court judgments for mistake, excusable neglect, newly discovered evidence, or fraud within one year, providing a clear remedial path to correct unjust outcomes.
Taxpayers and their representatives can obtain timely correction of clerical errors or omissions in Tax Court records, reducing the chance of unfair tax liabilities from simple mistakes.
Either party can obtain appellate review of orders granting relief within 90 days, creating clearer and faster reviewability of significant remedial decisions.
Taxpayers who discover issues after the one-year deadline may be barred from relief, limiting access to remedies for problems found late.
Taxpayers remain subject to enforcement (e.g., collection) because filing for relief does not suspend a judgment's finality, so relief efforts may not stop immediate collection actions.
Taxpayers may face increased litigation and motions practice in the Tax Court under the new relief authority, raising legal costs and potentially prolonging final resolution.
Based on analysis of 2 sections of legislative text.
Adds explicit Tax Court authority to correct clerical errors and to grant time-limited post-judgment relief on specified grounds with appellate rules.
Official title: Amend the Internal Revenue Code of 1986 to clarify the authority of the Tax Court to order relief from a judgment or order.
Introduced June 11, 2026 by Tim Scott · Last progress June 11, 2026
Adds a new post-judgment remedial mechanism to the Tax Court by amending 26 U.S.C. § 7481 to let the Tax Court correct clerical mistakes and to grant relief from final judgments or orders on specified grounds (mistake/inadvertence/excusable neglect; newly discovered evidence; fraud/misrepresentation/misconduct by an opposing party; void judgments; or other circumstances where justice requires). Motions for relief must be filed within a "reasonable time" and, for several listed grounds, no later than one year after entry; motions do not stay finality while pending; appellate review rules and timing for appeals from Tax Court orders are specified.