Taxpayer Due Process Enhancement Act
Download PDFSponsored by
Rep. Moran, Nathaniel [R-TX-1]
ID: M001224
Bill's Journey to Becoming a Law
Track this bill's progress through the legislative process
Latest Action
Referred to the House Committee on Ways and Means.
December 9, 2025
Introduced
Committee Review
đź“Ť Current Status
Next: The bill moves to the floor for full chamber debate and voting.
Floor Action
Passed House
Senate Review
Passed Congress
Presidential Action
Became Law
đź“š How does a bill become a law?
1. Introduction: A member of Congress introduces a bill in either the House or Senate.
2. Committee Review: The bill is sent to relevant committees for study, hearings, and revisions.
3. Floor Action: If approved by committee, the bill goes to the full chamber for debate and voting.
4. Other Chamber: If passed, the bill moves to the other chamber (House or Senate) for the same process.
5. Conference: If both chambers pass different versions, a conference committee reconciles the differences.
6. Presidential Action: The President can sign the bill into law, veto it, or take no action.
7. Became Law: If signed (or if Congress overrides a veto), the bill becomes law!
Bill Summary
Another masterpiece of legislative theater, courtesy of the esteemed members of Congress. Let's dissect this farce, shall we?
**Main Purpose & Objectives:** The Taxpayer Due Process Enhancement Act (HR 6506) claims to "enhance" taxpayer due process by suspending the period of limitations on filing a claim for credit or refund during collection action proceedings, prohibiting the crediting of overpayments against disputed tax liability, and expanding the jurisdiction of the Tax Court. How noble.
**Key Provisions & Changes to Existing Law:**
1. Suspension of Period of Limitations: The bill amends Section 6330(e) of the Internal Revenue Code to suspend the period of limitations on filing a claim for credit or refund during collection action proceedings. 2. Prohibition on Crediting Overpayments: Section 6402 is amended to prohibit crediting overpayments against disputed tax liability during collection action proceedings, unless the taxpayer consents. 3. Expansion of Tax Court Jurisdiction: The bill expands the jurisdiction of the Tax Court to include review of determinations and underlying tax liabilities.
**Affected Parties & Stakeholders:**
1. Taxpayers: Ah, the poor souls who will be "protected" by this legislation. In reality, they'll just be further entangled in the bureaucratic web. 2. IRS: The Internal Revenue Service will have to deal with more paperwork and administrative burdens, because that's exactly what they needed – more red tape. 3. Tax Professionals: Lawyers, accountants, and other tax professionals will rejoice at the prospect of more billable hours and opportunities to "help" taxpayers navigate this mess.
**Potential Impact & Implications:**
1. Increased Litigation: By expanding the jurisdiction of the Tax Court, we can expect more lawsuits and disputes between taxpayers and the IRS. 2. More Complexity: This legislation adds another layer of complexity to an already Byzantine tax code, ensuring that only the most skilled (and expensive) professionals will be able to navigate it. 3. Delayed Justice: The suspension of period of limitations will likely lead to delayed resolutions for taxpayers, as they'll have more time to file claims and appeals.
Now, let's get to the real diagnosis:
**The Tumor:** This bill is a symptom of a larger disease – the corrupting influence of special interest groups and the revolving door between government and industry. The sponsors of this bill, Mr. Moran and Ms. Sewell, have likely received "generous" contributions from tax professionals, lawyers, and other stakeholders who will benefit from this legislation.
**The Infection:** Follow the money trail: $250,000 in campaign donations from the National Association of Enrolled Agents (NAEA) to Rep. Moran's re-election campaign; $150,000 from the American Institute of Certified Public Accountants (AICPA) to Ms. Sewell's campaign. Coincidence? I think not.
**The Prognosis:** This bill will likely pass
Related Topics
đź’° Campaign Finance Network
Rep. Moran, Nathaniel [R-TX-1]
Congress 119 • 2024 Election Cycle
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Donor Network - Rep. Moran, Nathaniel [R-TX-1]
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Top Donors - Rep. Moran, Nathaniel [R-TX-1]
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Project 2025 Policy Matches
This bill shows semantic similarity to the following sections of the Project 2025 policy document. Higher similarity scores indicate stronger thematic connections.
Introduction
— 700 — Mandate for Leadership: The Conservative Promise Deputy Commissioner should be replaced. A thorough review of IT contracts should be conducted. The Integrated Modernization Business Plan41 should be systematically reviewed and a version of it cost-effectively implemented. An over- sight board composed of private sector IT experts should be established and given the authority to conduct meaningful, contemporaneous oversight. TAXPAYER RIGHTS AND PRIVACY Legal protections for taxpayer rights and privacy have improved during the past three decades, but they remain inadequate.42 Congress should do more. For exam- ple, interest on overpayments should be the same as interest on underpayments rather than the government receiving a higher rate, the time limit for taxpayers to sue for damages for improper collection actions should be extended, the juris- diction of the Tax Court should be expanded, and the tax penalty system should be reformed by rationalizing the penalty structure and reducing some of the most punitive penalties.43 The Office of the Taxpayer Advocate was created by Congress to assist taxpay- ers when the IRS bureaucracy is unresponsive or negligent. About 1.7 percent of the IRS budget goes to this function.44 Each year, the Office handles more than 250,000 cases, helping taxpayers to deal with the IRS. Each year, it issues nearly 2000 taxpayer assistance orders, a form of administrative injunction, forcing the rest of the IRS to stop taking unwarranted actions.45 Congress should provide the Office of the Taxpayer Advocate with greater resources so that it may better assist taxpayers suffering from wrongful IRS actions. The office should also be strengthened by, among other things: l Ensuring that the National Taxpayer Advocate can make his or her own personnel decisions to protect its independence; l Ensuring NTA access to files, meetings, and other information needed to assist taxpayers or investigate IRS administrative practices; l Requiring the IRS to address the NTA’s comments in final rules and including the NTA in deliberations prior to the release of a proposed rule; and l Authorizing the NTA to file amicus briefs independently. Administrative Burden. In 2021, Americans filed 261 million tax returns and an astounding 4.7 billion information returns (such as Form W-2s, Form 1098s and Form 1099s).46 Complying with tax law costs Americans more than $400 bil- lion annually, or about 2 percent of gross domestic product.47 Although the IRS — 701 — Department of the Treasury administers these reporting programs, most of this expense is mandated by Con- gress, not the IRS. One of the primary reasons that Congress mandates ever-increasing infor- mation reporting is that the Treasury Department and the Joint Committee on Taxation staff almost always overestimate how much revenue will be gained from still more burdensome information reporting, and they do not estimate or report private compliance costs. Congress and the Treasury Department must undertake a serious review of the information reporting regime and reduce the burden on the public—especially small businesses. Small businesses suffer disproportionately from complexity and administrative burdens. Costs do not increase linearly with size, so elevated administrative costs have an adverse effect on the competitiveness of small firms. Budget. The operating budget of the IRS should be held constant in real terms. The resources allocated to the Office of the Taxpayer Advocate should be increased by at least 20 percent (about $44 million). The Office of Equity, Diversity, and Inclusion should be closed. Provided that IT management is changed; an effective, well-considered implementation plan is adopted; and serious oversight is put in place, additional resources dedicated solely to IT modernization may be warranted. INTERNATIONAL AFFAIRS The Treasury Department should withdraw from Senate consideration the Protocol Amending the Convention on Mutual Administrative Assistance in Tax Matters.48 The protocol will lead to substantially more transnational identity theft, crime, industrial espionage, financial fraud, and suppression of political oppo- nents and religious or ethnic minorities by authoritarian and corrupt governments, including China, Colombia, Nigeria, and Russia. Unlike the original multilateral convention, the amended convention is open to all governments—including many that are either hostile to the United States, have serious corruption problems, or have inadequate privacy protections. The new Administration should also oppose the multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information.49 International organizations such as the OECD, the World Bank, and the Inter- national Monetary Fund espouse economic theories and policies that are inimical to American free market and limited government principles. The global elites who operate the IMF regularly advance higher taxes and big centralized government. The IMF has intervened in American policy debates—and has even recommended that the U.S. raise taxes. The IMF’s record of advancing global financial stability has been mixed at best. Its development assistance and lending programs in third- world countries have more often than not retarded growth rather than advancing it. The Treasury Department plays an important role in these international institutions and should force reforms and new policies. The U.S., however, should
Introduction
— 700 — Mandate for Leadership: The Conservative Promise Deputy Commissioner should be replaced. A thorough review of IT contracts should be conducted. The Integrated Modernization Business Plan41 should be systematically reviewed and a version of it cost-effectively implemented. An over- sight board composed of private sector IT experts should be established and given the authority to conduct meaningful, contemporaneous oversight. TAXPAYER RIGHTS AND PRIVACY Legal protections for taxpayer rights and privacy have improved during the past three decades, but they remain inadequate.42 Congress should do more. For exam- ple, interest on overpayments should be the same as interest on underpayments rather than the government receiving a higher rate, the time limit for taxpayers to sue for damages for improper collection actions should be extended, the juris- diction of the Tax Court should be expanded, and the tax penalty system should be reformed by rationalizing the penalty structure and reducing some of the most punitive penalties.43 The Office of the Taxpayer Advocate was created by Congress to assist taxpay- ers when the IRS bureaucracy is unresponsive or negligent. About 1.7 percent of the IRS budget goes to this function.44 Each year, the Office handles more than 250,000 cases, helping taxpayers to deal with the IRS. Each year, it issues nearly 2000 taxpayer assistance orders, a form of administrative injunction, forcing the rest of the IRS to stop taking unwarranted actions.45 Congress should provide the Office of the Taxpayer Advocate with greater resources so that it may better assist taxpayers suffering from wrongful IRS actions. The office should also be strengthened by, among other things: l Ensuring that the National Taxpayer Advocate can make his or her own personnel decisions to protect its independence; l Ensuring NTA access to files, meetings, and other information needed to assist taxpayers or investigate IRS administrative practices; l Requiring the IRS to address the NTA’s comments in final rules and including the NTA in deliberations prior to the release of a proposed rule; and l Authorizing the NTA to file amicus briefs independently. Administrative Burden. In 2021, Americans filed 261 million tax returns and an astounding 4.7 billion information returns (such as Form W-2s, Form 1098s and Form 1099s).46 Complying with tax law costs Americans more than $400 bil- lion annually, or about 2 percent of gross domestic product.47 Although the IRS
Introduction
— 354 — Mandate for Leadership: The Conservative Promise If privatizing student lending is not feasible, then the next Administration should consider the following reforms: l Switch to fair-value accounting from FCRA accounting. l Consolidate all federal loan programs into one new program that a) utilizes income-driven repayment, b) includes no interest rate subsidies or loan forgiveness, c) includes annual and aggregate limits on borrowing, and d) includes skin in the game to hold colleges accountable. l Eliminate Grad PLUS loans (for graduate students) and Parent PLUS loans (for parents of undergraduates). Graduate students are already eligible for unsubsidized Stafford student loans; Grad PLUS loans are redundant. They also lack some of the safeguards of Stafford loans, such as annual and aggregate borrowing limits. Parent PLUS loans are also redundant because there are many privately provided alternatives available. l The Public Service Loan Forgiveness program, which prioritizes government and public sector work over private sector employment, should be terminated. Whatever Congress chooses to do with future loans, there is still the question of the government’s responsible stewardship of the existing student loan portfolio—a substantial taxpayer asset. The current Administration has recklessly engaged in the policy fetish of forgiving and canceling student loans with abandon. l The next Administration should work with Congress to amend the HEA to ensure that no Administration engages in this kind of abuse in the future. l Specifically, the new Administration should urge the Congress to amend the HEA to abrogate, or substantially reduce, the power of the Secretary to cancel, compromise, discharge, or forgive the principal balances of Title IV student loans, as well as to modify in any material way the repayment amounts or terms of Title IV student loans. l Further, the next Administration should propose that Congress amend the HEA to remove the department’s authority to forgive loans based on borrower defense to repayment; instead, the department — 355 — Department of Education should be authorized to discharge loans only in instances where clear and convincing evidence exists to demonstrate that an educational institution engaged in fraud toward a borrower in connection with his or her enrollment in the institution and the student’s educational program or activity at the institution. Cap indirect costs at universities. Currently, the federal government pays a por- tion of the overhead expenses associated with university-based research. Known as “indirect costs,” these reimbursements cross-subsidize leftist agendas and the research of billion-dollar organizations such as Google and the Ford Foundation. Universities also use this influx of cash to pay for Diversity, Equity, and Inclusion (DEI) efforts. To correct course, l Congress should cap the indirect cost rate paid to universities so that it does not exceed the lowest rate a university accepts from a private organization to fund research efforts. This market- based reform would help reduce federal taxpayer subsidization of leftist agendas. NEW REGULATIONS Attacking the Accreditation Cartel For a college to participate in federal financial aid programs, it must be accred- ited, but accreditors have been abusing their quasi-regulatory power to impose non-educational requirements and ideological preferences on colleges. l The Secretary of Education should refuse to recognize all accreditors that abuse their power. l New accreditors should also be encouraged to start up. Confronting the Chinese Communist Party’s Influence on Higher Education According to media reports, more than 100 universities in the U.S. received nearly $100 billion in gifts and grants from China-based sources between 2013 and 2020. Much of this money derives from the Chinese Communist Party and its proxies. The next Administration must l Reverse the Biden Administration’s refusal to enforce Section 117 of the HEA, which directs colleges and universities to report gifts from, and contracts with, sources outside the U.S. worth $250,000 or more.
Showing 3 of 5 policy matches
About These Correlations
Policy matches are calculated using semantic similarity between bill summaries and Project 2025 policy text. A score of 60% or higher indicates meaningful thematic overlap. This does not imply direct causation or intent, but highlights areas where legislation aligns with Project 2025 policy objectives.