{"bill":{"id":"119-hr-6506","congress":119,"type":"HR","number":6506,"title":"Taxpayer Due Process Enhancement Act","originChamber":"House","introducedDate":"2025-12-09","sponsors":[{"bioguideId":"M001224","fullName":"Rep. Moran, Nathaniel [R-TX-1]","party":"R","state":"TX","district":1}],"cosponsorsCount":1,"latestAction":{"actionDate":"2026-05-20","text":"Received in the Senate and Read twice and referred to the Committee on Finance."},"policyArea":"Taxation","subjects":["Income tax credits","Jurisdiction and venue","Specialized courts","Tax administration and collection, taxpayers"],"actions":[{"date":"2026-05-20","text":"Received in the Senate and Read twice and referred to the Committee on Finance.","type":"IntroReferral","chamber":"Senate","hasVote":false},{"date":"2026-05-19","text":"Motion to reconsider laid on the table Agreed to without objection.","type":"Floor","chamber":"House floor actions","hasVote":false},{"date":"2026-05-19","text":"On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564)","type":"Floor","chamber":"House floor actions","hasVote":false},{"date":"2026-05-19","text":"Passed/agreed to in House: On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564)","type":"Floor","chamber":"Library of Congress","hasVote":false},{"date":"2026-05-19","text":"DEBATE - The House proceeded with forty minutes of debate on H.R. 6506.","type":"Floor","chamber":"House floor actions","hasVote":false},{"date":"2026-05-19","text":"Considered under suspension of the rules. (consideration: CR H3564-3567)","type":"Floor","chamber":"House floor actions","hasVote":false},{"date":"2026-05-19","text":"Mr. Smith (MO) moved to suspend the rules and pass the bill, as amended.","type":"Floor","chamber":"House floor actions","hasVote":false},{"date":"2026-01-07","text":"Placed on the Union Calendar, Calendar No. 373.","type":"Calendars","chamber":"House floor actions","hasVote":false},{"date":"2026-01-07","text":"Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.","type":"Committee","chamber":"House floor actions","hasVote":false},{"date":"2026-01-07","text":"Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.","type":"Committee","chamber":"Library of Congress","hasVote":false},{"date":"2025-12-10","text":"Ordered to be Reported in the Nature of a Substitute (Amended) by the Yeas and Nays: 41 - 0.","type":"Committee","chamber":"House committee actions","hasVote":false},{"date":"2025-12-10","text":"Committee Consideration and Mark-up Session Held","type":"Committee","chamber":"House committee actions","hasVote":false},{"date":"2025-12-09","text":"Referred to the House Committee on Ways and Means.","type":"IntroReferral","chamber":"House floor actions","hasVote":false},{"date":"2025-12-09","text":"Introduced in House","type":"IntroReferral","chamber":"Library of Congress","hasVote":false},{"date":"2025-12-09","text":"Introduced in House","type":"IntroReferral","chamber":"Library of Congress","hasVote":false}],"summary":"<p><strong>Taxpayer Due Process Enhancement Act</strong></p><p>This bill suspends the period of time allowed for claiming a federal tax refund (limitations period) during collection due process (CDP) proceedings, prohibits the Internal Revenue Service (IRS) from applying tax overpayments to a tax liability that is disputed in such proceedings, and expands the Tax Court’s jurisdiction.</p><p>As background, IRS collection actions and the underlying tax liability (in some circumstances) may be disputed in a CDP hearing. Collection actions are suspended during CDP proceedings, but the IRS may apply tax overpayments from other tax years to the disputed tax liability.&nbsp;The Tax Court may review an appeal of a CDP hearing determination. However, the Supreme Court held in <em>Commissioner v. Zuch</em> that&nbsp;the Tax Court loses jurisdiction over a CDP appeal if the CDP hearing determination is revoked because tax overpayments are applied to and fully satisfy the tax liability.&nbsp;In such circumstances, the taxpayer may claim a refund and seek redress in federal district court. Currently, the limitations period to file a refund claim is not suspended during CDP proceedings.</p><p>The bill</p><ul><li>suspends the limitations period for claiming a tax refund during CDP proceedings (with exceptions),</li><li>prohibits the IRS from applying tax overpayments to a properly disputed tax liability during CDP proceedings (unless waived or an exception applies),</li><li>expands the Tax Court's jurisdiction in CDP cases to include jurisdiction over the underlying tax liability amount (if properly disputed), and</li><li>provides that the Tax Court retains its jurisdiction if the IRS abandons collection actions.</li></ul>","updateDate":"2026-07-17T23:57:57Z"},"markets":[],"stateBills":[],"meta":{"sources":["congress.gov"],"latencyMs":463,"ts":"2026-08-28T08:39:24.722Z"},"nextActions":{"inspect":[],"related":[{"description":"Search related legislation","method":"GET","url":"https://simplefunctions.dev/api/public/query-gov?q=Taxpayer%20Due%20Process%20Enhancement%20Act"}]}}