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
II American Citizens Abroad
III Judicial Review
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 7463, as amended by this Act, is amended—
(1) by striking $50,000 each place it appears in subsections (a) and (f) and inserting $100,000, and
(2) by adding at the end the following new subsection:
(g) Inflation adjustment
(1) In general. In the case of any petition filed in a calendar year beginning after 2026, each of the $100,000 amounts in subsections (a) and (f) shall be increased by an amount equal to—
(A) such dollar amount, multiplied by
(B) the cost-of-living adjustment determined under section 1(f)(3) for the calendar year, determined by substituting calendar year 2025 for calendar year 2016 in subparagraph (A)(ii) thereof.
(2) Rounding. If any increase determined under paragraph (1) is not a multiple of $1,000, such increase shall be rounded to the next lowest multiple of $1,000.
(b) Proceedings for determination of employment status. Section 7436(c)(1) is amended by striking if the amount of employment taxes placed in dispute is $50,000 or less for each calendar quarter involved and inserting if the amount of employment taxes placed in dispute is equal to or less than the dollar amount in effect under section 7463(a)(1) (determined at the time the pleading is filed under subsection (a)) for each calendar quarter involved.
(c) Conforming amendments
(1) Section 7443A(b)(3) is amended by striking $50,000 and inserting the dollar amount in effect under section 7463(a)(1) (determined at the time the pleading is filed).
(2) Section 7463(f)(2) is amended by striking an appeal and inserting a petition.
(3) The heading for section 7463 is amended by striking Disputes involving $50,000 or less and inserting Small disputes.
(4) The item relating to section 7463 in the table of section for part II of subchapter C of chapter 76 is amended by striking Disputes involving $50,000 or less and inserting Small disputes.
(d) Effective date. The amendments made by this section shall apply to proceedings commencing after the date of the enactment of this Act.
IV Office of the Taxpayer Advocate
V Tax Return Preparers
VI Appeals
VII Whistleblowers
VIII Hostages
IX Small Businesses
X Miscellaneous