H.R. 5349
TAS Act
Sponsor: Nathaniel Moran
1 cosponsor
Official summary
Written by the Congressional Research Service.
Tax Court Improvement Act
This bill expands the authority of the U.S. Tax Court to issue subpoenas, authorizes the Tax Court to extend certain petition deadlines, and makes other changes related to Tax Court procedures.
The bill authorizes the Tax Court to issue subpoenas compelling the production of documents and other items from a litigant or witness for evidentiary or discovery purposes (whether or not it is in connection with a scheduled hearing). (Under current law, the Tax Court may issue subpoenas only to compel the attendance and testimony of witnesses and the production of evidence at a scheduled hearing or deposition.)
The bill authorizes the Tax Court to extend (or toll) the deadline to file a Tax Court petition contesting an Internal Revenue Service (IRS) deficiency notice if it is equitable to do so (known as equitable tolling). Further, under the bill, the dismissal of a petition contesting an IRS deficiency notice because the petition is not filed before the deadline and equitable tolling is denied is not treated as a decision of the Tax Court. This allows a subsequent claim to be filed in U.S. district court if certain conditions are met.
The bill also
- expands the type of Tax Court proceedings for which special trial judges may be appointed,
- authorizes Tax Court special trial judges to impose fines up to $5,000 and up to 30 days in jail for contempt of court, and
- requires Tax Court judges and special trial judges to recuse themselves in certain circumstances.
Text of the bill
I Tax Administration and Customer Service
Where this section came from
Not in the first version (Introduced in House, Sep 15).
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Sep 30, 2026 · Engrossed Amendment Senate S.Amdt. 6848: To amend the title. Official page › S.Amdt. 6847: In the nature of a substitute. Official page ›
(a) In general. Not later than 12 months after the date of enactment of this Act, the Secretary shall—
(1) establish a program to identify taxpayers who—
(A) are reasonably likely to be experiencing an economic hardship, and
(B) have an unpaid tax liability, and
(2) in the case of any taxpayer described in paragraph (1) who requests to enter into an agreement described in section 6159(a) of the Internal Revenue Code of 1986, provide such taxpayer with information regarding other options which the Internal Revenue Service makes available to taxpayers who have an unpaid tax liability and are experiencing an economic hardship, including—
(A) an agreement described in such section for partial collection of a tax liability,
(B) an offer-in-compromise (as described in section 7122 of such Code), and
(C) classification as currently not collectible (within the meaning of section 6343(e) of such Code).
(b) Economic hardship. For purposes of this section, in determining whether a taxpayer is reasonably likely to be experiencing an economic hardship, such determination shall be made in the same manner as determined under section 6343(a)(1)(D) of the Internal Revenue Code of 1986 based on—
(1) the most recent income and asset data which the Secretary has received from a return or a report from, or with respect to, such taxpayer, and
(2) the schedules described in section 7122(d)(2)(A) of such Code.
(c) Report. Not later than 2 years after the date of enactment of this Act, the Secretary, in consultation with the National Taxpayer Advocate, shall submit a report to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate regarding—
(1) the accuracy of the Internal Revenue Service with respect to identifying taxpayers who are reasonably likely to be experiencing an economic hardship under subsection (a)(1),
(2) whether such identification procedures may be appropriately applied for other purposes, and
(3)
(A) the number of taxpayers with an unpaid tax liability who were identified as reasonably likely to be experiencing an economic hardship under subsection (a)(1),
(B) the options described in subsection (a)(2) that were provided to such taxpayers, and
(C) the status of the tax liabilities of such taxpayers.
II American Citizens Abroad
III Judicial Review
IV Office of the Taxpayer Advocate
V Tax Return Preparers
VI Appeals
VII Whistleblowers
VIII Hostages
IX Small Businesses
X Miscellaneous