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HR-6506House2026-05-19Taxation

Taxpayer Due Process Enhancement Act

YourVoice.Now Summary

Your MoneyCivil Liberties

Pauses your refund deadline while you dispute an IRS tax bill — and the IRS needs your OK to use that refund.

Your Money

Time to claim a tax refund — paused during IRS collection appeals

There is a legal deadline for filing a claim to get a tax refund. That clock would stop while you appeal an IRS collection action, so a slow hearing does not cost you the claim.

Refunds kept during a tax dispute — IRS needs your consent

Today the IRS can take a refund from one year and put it toward a tax bill from another year. It could not do that with a bill you dispute, unless you agree.

Civil Liberties

Challenges allowed at IRS collection hearings — covers actions already taken

At a hearing today you can raise issues about the unpaid tax or a levy the IRS plans. This would add steps the IRS already took, such as a lien on your property.

Court review of the disputed bill — the amount, not just procedure

Today the Tax Court mostly checks whether the IRS followed its rules. It could also decide how much tax you owe, if you disputed that amount at your hearing.

Missed 30-day court deadline — judges could excuse it

You get 30 days after a hearing decision to take your case to the Tax Court. The court could decide whether a late filing should still be allowed for reasons of fairness.

Court case survives if IRS drops the collection action

The IRS can end a collection action after a hearing decision, which can knock the case out of court. The Tax Court would keep the case either way, so dropping the collection would not end your challenge.

More about this bill

If you are disputing an IRS tax bill, you could keep your refund rights while you wait. Today the deadline to claim a tax refund keeps running during an IRS collection appeal. A long hearing can run that clock out. Under this change, the clock would pause for the tax bill you disputed. The pause would end if a court or a missed deadline ends your right to keep disputing. The IRS also could not put a refund you are owed toward that disputed bill without your consent. The bill would also change what hearings and courts can do. You could raise more issues at your hearing, including collection steps the IRS already took. The Tax Court could rule on how much you owe, not just on whether the IRS followed its rules. It could also excuse a late court filing when fairness calls for it. Your case would stay in court even if the IRS drops the collection action. These changes would start when the bill becomes law. It passed the House in May 2026 and now sits with a Senate committee.

Congressional Summary

Taxpayer Due Process Enhancement Act This bill suspends the period of time allowed for claiming a federal tax refund (limitations period) during collection due process (CDP) proceedings, prohibits the Internal Revenue Service (IRS) from applying tax overpayments to a tax liability that is disputed in such proceedings, and expands the Tax Court’s jurisdiction. As background, IRS collection actions and the underlying tax liability (in some circumstances) may be disputed in a CDP hearing. Collection actions are suspended during CDP proceedings, but the IRS may apply tax overpayments from other tax years to the disputed tax liability. The Tax Court may review an appeal of a CDP hearing determination. However, the Supreme Court held in Commissioner v. Zuch that the Tax Court loses jurisdiction over a CDP appeal if the CDP hearing determination is revoked because tax overpayments are applied to and fully satisfy the tax liability. In such circumstances, the taxpayer may claim a refund and seek redress in federal district court. Currently, the limitations period to file a refund claim is not suspended during CDP proceedings. The bill suspends the limitations period for claiming a tax refund during CDP proceedings (with exceptions), prohibits the IRS from applying tax overpayments to a properly disputed tax liability during CDP proceedings (unless waived or an exception applies), expands the Tax Court's jurisdiction in CDP cases to include jurisdiction over the underlying tax liability amount (if properly disputed), and provides that the Tax Court retains its jurisdiction if the IRS abandons collection actions.

Legislative Subjects

Income tax creditsJurisdiction and venueSpecialized courtsTax administration and collection, taxpayers

Details

Congress
119th
Chamber
House
Status
summarized
Action
Passed House
Action Date
2026-05-19
Date Added
2026-04-25
Source
Congress.gov →

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