H.R. 5349

TAS Act

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

Expand all

I Tax Administration and Customer Service

Sec. 107. Installment agreement fees eliminated for certain individuals 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) In general. Section 6159(f) is amended by striking paragraph (2) and inserting the following:

Text this section adds to the law

(2) Waiver. No fee shall be imposed on an installment agreement under this section in the case of any taxpayer with an adjusted gross income, as determined for the most recent year for which such information is available, which does not exceed 250 percent of the applicable poverty level (as determined by the Secretary).

(b) Effective date. The amendment made by this section shall apply to installment agreements entered into after the date which is 12 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