H.R. 5349

TAS Act

Sponsor: Nathaniel Moran

1 cosponsor
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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

Expand all

I Tax Administration and Customer Service

Sec. 110. Low-income taxpayer clinic funding unlocked Added Sep 30

Where this section came from

Not in the first version (Introduced in House, Sep 15).

  1. 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) Matching funds. Paragraph (5) of section 7526(c) is amended to read as follows:

Text this section adds to the law

(5) Requirement of matching funds

(A) In general. With respect to any grant provided to a low-income taxpayer clinic under this section, such clinic shall provide matching funds equal to the applicable percentage of the amount of such grant.

(B) Matching funds

(i) In general. For purposes of this paragraph, the term matching funds may include—

(I) the salary (including fringe benefits) of individuals performing services for the low-income taxpayer clinic, and

(II) the cost of equipment used in the low-income taxpayer clinic.

(ii) Exclusion. For purposes of this paragraph, the term matching funds shall not include any indirect expenses, such as general overhead of the institution sponsoring the low-income taxpayer clinic.

(C) Applicable percentage. For purposes of subparagraph (A), the applicable percentage shall be 100 percent, except that the Secretary may establish a lower percentage (not below 25 percent) if the Secretary determines that such percentage would expand the coverage of the low-income taxpayer clinic to additional taxpayers.

(b) Technical amendments. Section 7526(c), as amended by subsection (a), is further amended—

(1) by striking paragraphs (1) and (2), and

(2) by redesignating paragraphs (3) through (6) as paragraphs (1) through (4).

(c) Effective date. The amendments made by this section shall apply to calendar years beginning 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