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. Section 7524 is amended—
(1) in the heading, by striking Annual notice and inserting Notice,
(2) by striking Not less often than annually and inserting the following:
(a) In general. Except as provided in subsection (c), not less often than quarterly
, and
(3) by adding at the end the following:
(b) Information on penalties and interest. The notice described in subsection (a) shall include—
(1) an estimate of the amount of penalties and interest that may accrue if the delinquent tax debt is not fully paid within the period remaining under section 6502(a), and
(2) programs and services that can provide assistance to the taxpayer.
(c) Exception. The requirement under subsection (a) shall not apply—
(1) during any period in which an agreement described in section 6159(a) or an accepted offer-in-compromise (as described in section 7122) is in effect, or
(2) in the case of a taxpayer for which the Secretary has determined that the tax is not collectible (within the meaning of section 6343(e)).
(b) Conforming amendment. The table of sections for chapter 77 is amended by striking the item relating to section 7524 and inserting the following new item:
Sec. 7524. Notice of tax delinquency.
(c) Effective date. The amendments made by this section shall take effect on the date which is 24 months after the date of enactment of this Act.
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