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H.R. 6506: Taxpayer Due Process Enhancement Act
119th Congress · introduced 2025-12-09 · Taxation · Latest: Received in the Senate and Read twice and referred to the Committee on Finance.
federal
Official title
Taxpayer Due Process Enhancement Act
Plain 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.
Congressional Research Service summary (Reported to House), quoted unchanged (nonpartisan). Read the source.
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What does this mean? (plain words)
Official text
Taxpayer Due Process Enhancement Act
Source: Congressional Research Service summary (Reported to House)
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Officials and money
Sponsor: Rep. Moran, Nathaniel [R-TX-1] · 1 cosponsors
Money: CBO cost estimate: H.R. 6506, Taxpayer Due Process Enhancement Act (2026-02-05) No linked contracts or vendors yet.
Words on this page, explained (2)
- Bill
- A proposed law. It becomes law only if it passes the legislature and is signed by the president or governor (or a veto is overridden).
- Jurisdiction
- The area or the matters a government or court has authority over.
Plain meanings written from linked sources. All words.
Sources
- Congressional Research Service summary (Reported to House)
- Congress.gov
- Data: GovInfo BILLSTATUS bulk data (Library of Congress), BILLSTATUS-119hr6506.xml <https://www.govinfo.gov/bulkdata/BILLSTATUS/119/hr>
Record fed-us-cong119-hr6506 · catalog fed-us-congress-bills-cong119 · updated 2026-11-03 by psicol fed-bills