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).
-
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) Returns accepted electronically. Any Federal tax return which any person is required to file with the Secretary, as well as any amendments to such return—
(1) may be filed by such person electronically, and
(2) if such return or amendment is filed electronically, shall be processed electronically by the Secretary.
(b) Digitization of returns and correspondence. The Internal Revenue Service shall use optical character recognition technology (or any functionally similar technology) to transcribe—
(1) any return which is received by the Internal Revenue Service only in a paper form, or
(2) any correspondence which is received by the Internal Revenue Service only in a paper form.
(c) Exceptions
(1) In general. Subsection (b) shall not apply to any technology to the extent that the Secretary determines such technology is slower or less reliable than—
(A) the process of manually transcribing returns or correspondence received in a paper form, or
(B) any other process that the Internal Revenue Service is using or would otherwise use.
(2) Report to congress. Any exception to the application of a technology described in subsection (b) pursuant to paragraph (1) shall not take effect unless the Secretary provides a report to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate regarding the determination made by the Secretary under such paragraph within 30 days of such determination.
(d) Effective date. This section shall apply to—
(1) any individual income tax return (as defined in section 6011(e)(3)(C) of the Internal Revenue Code of 1986) received on or after January 1 of the first calendar year beginning more than 180 days after the date of enactment of this Act,
(2) any estate tax return (as described in section 6018 of such Code) or gift tax return (as described in section 6019 of such Code) received on or after January 1 of the first calendar year beginning more than 24 months after the date of enactment of this Act, and
(3) any other return or correspondence received on or after January 1 of the first calendar year beginning more than 18 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