WASHINGTON, D.C. – American taxpayers will be assured their day in court should they have a dispute with the Internal Revenue Service (IRS) over alleged outstanding tax liabilities thanks to bipartisan legislation approved by the U.S. House of Representatives. The Taxpayer Due Process Enhancement Act (H.R. 6506), introduced by Representative Nathaniel Moran (TX-01) and Representative Terri Sewell (AL-07), strengthens taxpayer rights by making IRS collection proceedings more taxpayer-friendly, protecting the integrity of compliance deadlines, safeguarding refunds from being unfairly taken by the IRS, and ensuring fair judicial review of tax liability claims.
Ways and Means Committee Chairman Jason Smith (MO-08) issued the following statement on House passage of legislation to secure stronger taxpayer protections:
“Uncle Sam should not be able to circumvent the basic rights of American citizens. Unfortunately, right now, we have tax laws and judicial rulings that undermine taxpayer rights and could allow the IRS to impose penalties on individuals absent any judicial review. Thankfully, the House has acted to right this wrong and ensure American taxpayers are afforded their day in court.”
Taxpayer Due Process Enhancement Act (H.R. 6506):
- The U.S. Tax Court is a federal trial court which specializes in adjudicating disputes over federal income tax.
- If someone owes federal tax and does not pay, the IRS can seize property or place a legal claim on it. Before doing this, the agency must send the taxpayer a notice that explains that the taxpayer has the right to ask for a collection due process (CDP) hearing to challenge the IRS decision.
- A June 2025 Supreme Court decision ruled the Tax Court cannot hear a CDP appeal if the IRS drops its attempt to seize property and instead chooses a different method to take the taxpayer’s assets.
- In response to the Supreme Court’s ruling, this bill suspends the period of limitations for filing a claim for credit or refund during a CDP proceeding, giving taxpayers more time to receive their refunds.
- The bill also blocks the IRS from applying a taxpayer’s overpayment to any tax they are currently disputing and expands Tax Court’s CDP jurisdiction.
Read a fact sheet on the bill here.
The bill passed the Ways and Means Committee with a vote of 41-0.
The bill was approved by the U.S. House of Representatives with unanimous consent.
