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LEGISLATION/S. 4964

Protecting Innocent Taxpayers from Endless Assessments Act

119-S-4964119th CongressIntroduced Jul 14, 2026Taxation
Market Probability
No market
Status
Introduced
Committee
Floor Vote
Other Chamber
Signed
Read twice and referred to the Committee on Finance.

Sponsor

Sen. Marshall, Roger [R-KS](R-KS)
1 cosponsor

Summary

Protecting Innocent Taxpayers from Endless Assessments Act

This bill limits the amount of time the Internal Revenue Service (IRS) has to assess taxes related to fraudulent or false federal tax returns where there is no intent by the taxpayer to evade taxes.

As background, the IRS generally has three years from the date that a tax return is filed (statute of limitations) to assess taxes owed by the taxpayer for the tax year. However, if a false or fraudulent tax return is filed with the intent to evade tax (fraud exception), then the IRS may assess taxes at any time. In Murrin v. Commissioner the U.S. Tax Court held (and the U.S. Court of Appeals for the Third Circuit affirmed) that the fraud exception applies when a tax return preparer places false or fraudulent entries on a tax return without the taxpayer’s knowledge. In contrast, the U.S. Court of Federal Claims held in BASR Partnership v. Commissioner that the fraud exception only applies if the taxpayer intends to evade taxes.

The bill limits the fraud exception to cases in which the taxpayer intends to evade taxes.

Actions (2)

Read twice and referred to the Committee on Finance.
Jul 14, 2026Senate
Introduced in Senate
Jul 14, 2026Library of Congress