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
VI Appeals
VII Whistleblowers
VIII Hostages
IX Small Businesses
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 7502(c) is amended—
(1) in the heading, by inserting and payment after filing,
(2) in paragraph (2)—
(A) in the heading, by striking ; electronic filing, and
(B) by striking and electronic filing, and
(3) by adding at the end the following:
(3) Electronic filing and payment
(A) In general. In the case of any document or payment which the Secretary has permitted to be filed or made by electronic means, if such document or payment is— the date that such document or payment was authorized to be submitted (as described in clause (i)) shall be deemed to be the date that such document was filed or such payment was made.
(i) authorized to be submitted by the taxpayer using a permitted electronic means to the agency, officer, or office to which the document was required to be filed (or payment was required to be made) on or before the prescribed date (or within the period required) with respect to such document or payment, and
(ii) received (or, in the case of a payment, received and accounted for) no later than 3 business days after the prescribed date or period required with respect to such document or payment,
(B) Exception. This paragraph shall not apply to any payment if the Secretary determines that the taxpayer (or any intermediary used by the taxpayer) used a system designed with a principal purpose of delaying the transfer of funds to the Treasury to derive economic benefit from the period of such delay.
(C) Regulations. Not later than the date which is 1 year after the date of enactment of the Taxpayer Assistance and Service Act, the Secretary shall issue such regulations or other guidance as the Secretary determines necessary to carry out the purposes of this paragraph, including regulations or other guidance describing the records or proof sufficient to demonstrate timely electronic submission.
(b) Effective date. The amendments made by subsection (a) shall apply to any document or payment sent on or after the date which is 1 year after the date of enactment of this Act.
X Miscellaneous