S. 4964: Protecting Innocent Taxpayers from Endless Assessments Act

119th Congress · introduced 2026-07-14 · Taxation · Latest: Read twice and referred to the Committee on Finance.

federal

Official title

Protecting Innocent Taxpayers from Endless Assessments Act

Plain summary

Protecting Innocent Taxpayers from Endless Assessments Act This bill limits the amount of time the Internal Revenue Service (IRS) has to assess taxes related to fraudulent or false federal tax returns where there is no intent by the taxpayer to evade taxes. As background, the IRS generally has three years from the date that a tax return is filed (statute of limitations) to assess taxes owed by the taxpayer for the tax year. However, if a false or fraudulent tax return is filed with the intent to evade tax (fraud exception), then the IRS may assess taxes at any time. In Murrin v. Commissioner the U.S. Tax Court held (and the U.S. Court of Appeals for the Third Circuit affirmed) that the fraud exception applies when a tax return preparer places false or fraudulent entries on a tax return without the taxpayer’s knowledge. In contrast, the U.S. Court of Federal Claims held in BASR Partnership v. Commissioner that the fraud exception only applies if the taxpayer intends to evade taxes. The bill limits the fraud exception to cases in which the taxpayer intends to evade taxes.

Congressional Research Service summary (Introduced in Senate), quoted unchanged (nonpartisan). Read the source.

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Official text

Protecting Innocent Taxpayers from Endless Assessments Act

Source: Congressional Research Service summary (Introduced in Senate)

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Officials and money

Sponsor: Sen. Marshall, Roger [R-KS] · 1 cosponsors

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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).
Statute: A written law passed by a legislature. A statute can be changed by a later law; changing a constitution needs an amendment.

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Sources

Congressional Research Service summary (Introduced in Senate)
Congress.gov
Data: GovInfo BILLSTATUS bulk data (Library of Congress), BILLSTATUS-119s4964.xml <https://www.govinfo.gov/bulkdata/BILLSTATUS/119/s>

Record fed-us-cong119-s4964 · catalog fed-us-congress-bills-cong119 · updated 2026-11-03 by psicol fed-bills