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
IV Office of the Taxpayer Advocate
V Tax Return Preparers
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) Other assessable penalties with respect to the preparation of tax returns for other persons. Section 6695, as amended by the preceding provisions of this Act, is amended—
(1) in subsection (a)—
(A) by striking $50 and inserting $250, and
(B) by striking $25,000 and inserting $50,000,
(2) in subsection (b)—
(A) by striking $50 and inserting $250, and
(B) by striking $25,000 and inserting $75,000,
(3) in subsection (d)—
(A) by striking $50 and inserting $250, and
(B) by striking $25,000 and inserting $50,000,
(4) in subsection (e)—
(A) by striking $50 and inserting $250, and
(B) by striking $25,000 and inserting $75,000,
(5) in subsection (g), by striking $500 and inserting $1,000, and
(6) in subsection (i)(1)—
(A) by striking 2014 and inserting 2025, and
(B) by striking calendar year 2013 and inserting calendar year 2024.
(b) Misappropriation of refunds
(1) In general. Subsection (f) of section 6695 is amended to read as follows:
(f) Misappropriation
(1) In general. Any person who is a tax return preparer who misappropriates any payment made in respect of the taxes imposed by this title which is issued to a taxpayer (other than the tax return preparer) shall pay a penalty in an amount determined under paragraph (2).
(2) Penalty. The amount of the penalty determined under this paragraph shall, with respect to each payment described in paragraph (1), be equal to the greater of—
(A) $1,000, or
(B) the full amount of such payment.
(3) Exception. Paragraph (1) shall not apply with respect to the deposit by a bank (within the meaning of section 581) of the full amount of the payment in the taxpayer's account in such bank for the benefit of the taxpayer.
(2) Conforming amendment. Section 6695(i)(1) is amended by striking (f), and inserting (f)(2)(A),.
VI Appeals
VII Whistleblowers
VIII Hostages
IX Small Businesses
X Miscellaneous