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

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I Tax Administration and Customer Service

II American Citizens Abroad

Sec. 201. Report on combined tax and foreign bank and financial account reporting 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) Study

(1) In general. The Secretary shall conduct a study on—

(A) combining and simplifying reporting required under section 5314 of title 31, United States Code and sections 6038, 6038A, 6038B, 6038C, 6038D, 6039F, 6046A, and 6048 of the Internal Revenue Code of 1986; and

(B) eliminating duplicative requests for information from nonresident United States taxpayers.

(2) Consultation. The study conducted under paragraph (1) shall include input from the National Taxpayer Advocate and nonresident United States taxpayers.

(b) Report. Not later than 180 days after the date of enactment of this Act, the Secretary shall submit to Congress a report on the study conducted under subsection (a), which shall include any actions taken by the Secretary as a result of such study and any recommendations for legislative changes necessary to effectuate the goal described in subsection (a)(1).

III Judicial Review

IV Office of the Taxpayer Advocate

V Tax Return Preparers

VI Appeals

VII Whistleblowers

VIII Hostages

IX Small Businesses

X Miscellaneous