TAS Act

[Congressional Bills 119th Congress] [From the U.S. Government Publishing Office] [S. 5441 Reported in Senate (RS)]

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Calendar No. 670 119th CONGRESS 2d Session S. 5441

[Report No. 119-145]

To improve services provided to taxpayers by the Internal Revenue Service.

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IN THE SENATE OF THE UNITED STATES

September 17, 2026

Mr. Crapo, from the Committee on Finance, reported the following original bill; which was read twice and placed on the calendar

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A BILL

To improve services provided to taxpayers by the Internal Revenue Service.

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,

SECTION 1. SHORT TITLE; ETC.

(a) Short Title.--This Act may be cited as the ``Taxpayer Assistance and Service Act'' or the ``TAS Act''. (b) Amendment of 1986 Code.--Except as otherwise expressly provided, whenever in this Act an amendment is expressed in terms of an amendment to a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1986. (c) References to Secretary.--For purposes of this Act, the term ``Secretary'' means the Secretary of the Treasury or the Secretary's delegate. (d) Table of Contents.--The table of contents of this Act is as follows:

Sec. 1. Short title; etc. TITLE I--TAX ADMINISTRATION AND CUSTOMER SERVICE

Sec. 101. Digitization of tax returns and correspondence. Sec. 102. Establishment of dashboard to inform taxpayers of backlogs and wait times. Sec. 103. Expansion of electronic access to information about returns and refunds. Sec. 104. Expansion of callback technology. Sec. 105. Expansion of online accounts. Sec. 106. Automation of refund offset bypass. Sec. 107. Installment agreement fees eliminated for certain individuals. Sec. 108. Individuals facing economic hardships informed of collection alternatives. Sec. 109. Quarterly notices to certain taxpayers with delinquencies. Sec. 110. Low-income taxpayer clinic funding unlocked. Sec. 111. Chief Counsel reviews of offers-in-compromise streamlined. Sec. 112. Modification of procedural requirements for penalties and disallowance periods. Sec. 113. Return of amounts collected by IRS in excess of accepted offer-in-compromise amount. Sec. 114. Extension of period for return of amounts subject to wrongful levy. Sec. 115. Reports to Congress. TITLE II--AMERICAN CITIZENS ABROAD

Sec. 201. Report on combined tax and foreign bank and financial account reporting. Sec. 202. Study and reports on simplification. Sec. 203. Extension of time for persons outside of the United States to request abatement of math error. Sec. 204. Clarification of assessment authority; pre-assessment appeals of foreign information return penalties. Sec. 205. Repeal of due date requirements for certain information returns relating to foreign gifts and trusts. TITLE III--JUDICIAL REVIEW

Sec. 301. Authorization of subpoenas before hearings to facilitate settlements. Sec. 302. Clarification of Tax Court authority to order relief from a judgment or order. Sec. 303. Authorization of special trial judges to hear additional cases and address contempt. Sec. 304. Disqualification of judges and special trial judges. Sec. 305. Notice and review with respect to multi-year bans on claiming credits. Sec. 306. Authorization of de novo review of innocent spouse relief by the Tax Court and other courts. Sec. 307. Clarification of certain court filing deadlines. Sec. 308. Clarification of Tax Court jurisdiction to determine tax liability in collection due process appeals. Sec. 309. Authorization of the Tax Court to issue refunds in collection due process cases. Sec. 310. Authorization of the Tax Court to hear suits for refunds or credits. Sec. 311. Authorization to allow claims for refund in certain cases where full tax not paid. Sec. 312. Adjustment of threshold for small disputes. TITLE IV--OFFICE OF THE TAXPAYER ADVOCATE

Sec. 401. NTA authorization to direct hire attorneys. Sec. 402. NTA authorization to make personnel decisions. Sec. 403. Access to Internal Revenue Service information, legal advice, and meetings. Sec. 404. Repeal of limitation period suspension for taxpayers seeking assistance from TAS. Sec. 405. Operations to assist taxpayers experiencing hardships during lapse in appropriations. TITLE V--TAX RETURN PREPARERS

Sec. 501. Penalties for tax return preparers who improperly alter returns. Sec. 502. Ensuring the use of valid preparer identification numbers and electronic filing identification numbers. Sec. 503. Penalties for improper tax preparation or misappropriation of refunds. Sec. 504. Authority to deny, revoke, or suspend preparer tax identification numbers. TITLE VI--APPEALS

Sec. 601. Authorization for Office of Appeals to hire attorneys. Sec. 602. Authorization for Office of Appeals to direct hire certain individuals. Sec. 603. Responses to claims for refund required; appeal of claims for refund authorized. Sec. 604. Appeals of returned offers. Sec. 605. Purposes and duties of Independent Office of Appeals; right of appeal clarified. TITLE VII--WHISTLEBLOWERS

Sec. 701. Standard and scope of review of whistleblower award determinations. Sec. 702. Exemption from sequestration. Sec. 703. Whistleblower privacy protections. Sec. 704. Modification of IRS whistleblower report. Sec. 705. Interest on whistleblower awards. Sec. 706. Correction regarding deductions for attorney's fees. TITLE VIII--HOSTAGES

Sec. 801. Postponement of tax deadlines for hostages and individuals wrongfully detained abroad. Sec. 802. Refund and abatement of penalties and fines paid by eligible individuals. TITLE IX--SMALL BUSINESSES

Sec. 901. Implementation of voluntary withholding agreements for payments to independent contractors. Sec. 902. Extension of mailbox rule to electronic submissions and payments. Sec. 903. Specificity of third-party contact notices. Sec. 904. Modification of estimated tax rules for farmers and fishermen. Sec. 905. Business child care liaison. TITLE X--MISCELLANEOUS

Sec. 1001. Authority for redisclosure of certain tax information related to education loans to the Congressional Budget Office. Sec. 1002. Authorization to require large partnerships to file on magnetic media. Sec. 1003. Limitation period not extended for victims of preparer fraud. Sec. 1004. Technical amendment related to the Disaster Related Extension of Deadlines Act. Sec. 1005. Time for filing certain information returns. Sec. 1006. Modifications to penalties for unauthorized disclosures of taxpayer information.

TITLE I--TAX ADMINISTRATION AND CUSTOMER SERVICE

SEC. 101. DIGITIZATION OF TAX RETURNS AND CORRESPONDENCE.

(a) Returns Accepted Electronically.--Any Federal tax return which any person is required to file with the Secretary, as well as any amendments to such return-- (1) may be filed by such person electronically, and (2) if such return or amendment is filed electronically, shall be processed electronically by the Secretary. (b) Digitization of Returns and Correspondence.--The Internal Revenue Service shall use optical character recognition technology (or any functionally similar technology) to transcribe-- (1) any return which is received by the Internal Revenue Service only in a paper form, or (2) any correspondence which is received by the Internal Revenue Service only in a paper form. (c) Exceptions.-- (1) In general.--Subsection (b) shall not apply to any technology to the extent that the Secretary determines such technology is slower or less reliable than-- (A) the process of manually transcribing returns or correspondence received in a paper form, or (B) any other process that the Internal Revenue Service is using or would otherwise use. (2) Report to congress.--Any exception to the application of a technology described in subsection (b) pursuant to paragraph (1) shall not take effect unless the Secretary provides a report to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate regarding the determination made by the Secretary under such paragraph within 30 days of such determination. (d) Effective Date.--This section shall apply to-- (1) any individual income tax return (as defined in section 6011(e)(3)(C) of the Internal Revenue Code of 1986) received on or after January 1 of the first calendar year beginning more than 180 days after the date of enactment of this Act, (2) any estate tax return (as described in section 6018 of such Code) or gift tax return (as described in section 6019 of such Code) received on or after January 1 of the first calendar year beginning more than 24 months after the date of enactment of this Act, and (3) any other return or correspondence received on or after January 1 of the first calendar year beginning more than 18 months after the date of enactment of this Act.

SEC. 102. ESTABLISHMENT OF DASHBOARD TO INFORM TAXPAYERS OF BACKLOGS AND WAIT TIMES.

(a) In General.--The Secretary shall require the Internal Revenue Service to provide in real time on its public website, to the extent practical, the following: (1) Separately with respect to each applicable phone number extension-- (A) the number of callers connected to speak directly with a representative of the Internal Revenue Service, (B) the number of callers connected to speak with an automated system, (C) the number of callers who are waiting to be connected to speak directly with a representative of the Internal Revenue Service or an automated system, (D) the longest amount of time that any caller has been waiting to be connected to speak directly with a representative of the Internal Revenue Service, and (E) whether callback service is currently available, and if not, when such service is scheduled to be available. (2) An application or tool embedded on the website which-- (A) displays all of the information described in paragraph (1), and (B) estimates the approximate wait time to speak directly with a representative of the Internal Revenue Service. (3) An application programming interface which allows any person to access the information described in subsection (a)(1) using automation and to create an application or tool embedded on a website to display such information. (4) For each applicable phone number extension, a summary of the information described in paragraph (1) with respect to the prior month, including-- (A) the average and median length of calls, (B) the average and median amount of time that callers were speaking directly with a representative of the Internal Revenue Service, (C) the number and percent of calls that were directed to an automated system, (D) the number and percent of calls that were disconnected or terminated by the Internal Revenue Service, (E) the number of callers who were transferred to another applicable phone number extension after the call was initially answered by a representative of the Internal Revenue Service, (F) the average and median amount of time that callers described in subparagraph (E) were on hold following the transfer, and (G) the number and percent of callers who indicated that they received the answers or service for which they were contacting the Internal Revenue Service. (b) Detection of Automated Calls.--The Secretary shall require the Internal Revenue Service to use technology to detect and screen out automated calls. (c) Information Regarding Delays.--For any week in which there was a significant delay with respect to any applicable item (referred to in this subsection as an ``applicable week''), the Secretary shall require the Internal Revenue Service to provide on its public website, during the week subsequent to the applicable week, information with respect to each such applicable item regarding the earliest date on which any such applicable items that were processed during the applicable week were received by the Internal Revenue Service. (d) Definitions.-- For purposes of this section-- (1) Applicable item.--The term ``applicable item'' means each category of tax return, claim, statement, or other document filed with the Internal Revenue Service. (2) Applicable phone number extension.--The term ``applicable phone number extension'' means any extension or application which may be reached by calling a phone number which is listed by the Internal Revenue Service on any website, publication, form, or instruction which is available to the public and-- (A) operated by the Internal Revenue Service accounts management function, (B) operated by the Internal Revenue Service automated collection function, (C) managed by the Internal Revenue Service Joint Operations Center, (D) managed and staffed by a contractor on behalf of the Internal Revenue Service, or (E) received not less than 200,000 calls during the preceding calendar year. (3) Significant delay.--The term ``significant delay'' means, in the case of any applicable item for any week, the failure to process all of such applicable items which were received by the Internal Revenue Service at least 21 days before the first day of the week. (e) Effective Date.--The requirements of this section shall apply to periods beginning after the date which is 12 months after the date of enactment of this Act.

SEC. 103. EXPANSION OF ELECTRONIC ACCESS TO INFORMATION ABOUT RETURNS AND REFUNDS.

Not later than January 1 of the first calendar year beginning more than 12 months after the date of enactment of this Act, through a website and mobile application, the Secretary shall provide individualized, specific, and up-to-date information to taxpayers regarding their tax returns and amended returns, including information with respect to whether the Internal Revenue Service has-- (1) received such return and entered such return into their systems, (2) completed processing such return, including-- (A) the date on which the Internal Revenue Service issued any refund of any overpayment of tax, (B) the estimated date on which the taxpayer can expect to receive such refund, and (C)(i) if the refund will be issued by electronic fund transfer, the financial account to which such refund will be deposited, including-- (I) the partial or full account number for such account, and (II) the name and routing number of the financial institution, or (ii) if the refund will be issued by paper check, the address to which the check will be mailed, or (3) suspended processing such return, including-- (A) the reason for the suspension, and (B) in the case of any information which was requested by the Internal Revenue Service-- (i) the information requested, (ii) the form and manner for submission of such information, and (iii) the date on which such information is due to be submitted to the Internal Revenue Service.

SEC. 104. EXPANSION OF CALLBACK TECHNOLOGY.

It is the sense of Congress that-- (1) taxpayers contacting the Internal Revenue Service should have the option to receive a callback, and (2) not later than calendar year 2028, the Internal Revenue Service should provide any taxpayer (including any taxpayer residing outside of the United States) the option to receive a callback for any call made by the taxpayer to an applicable phone number extension (as defined in section 102(d)(2) of this Act) which has not been answered within 5 minutes.

SEC. 105. EXPANSION OF ONLINE ACCOUNTS.

(a) In General.--Not later than January 1 of the first calendar year beginning more than 18 months after the date of enactment of this Act, the Secretary shall make available a website or mobile application which allows any taxpayer (including any taxpayer residing outside of the United States) the ability to-- (1) in a manner consistent with any applicable limitations under section 6103 of the Internal Revenue Code of 1986, view any return (as defined in section 6103(b)(1) of the Internal Revenue Code of 1986), document, notice, or letter (with the exception of any educational item which has no legal effect) which, during the applicable period (as defined in subsection (d)), has been-- (A) sent by the Internal Revenue Service to such taxpayer, or (B) filed with (or, in the case of any document not required to be filed, sent to) the Internal Revenue Service-- (i) by such taxpayer, (ii) by a person described in subsection (c) of section 6103 of the Internal Revenue Code of 1986 with respect to such taxpayer, or (iii) with respect to such taxpayer in a manner described in subsection (e) of such section, (2) with respect to any document, notice, or letter sent to such taxpayer by the Internal Revenue Service, respond to such document, notice, or letter by uploading or otherwise transmitting the taxpayer's response through the website or mobile application, and (3) in the case of-- (A) any representative of such taxpayer who is authorized to practice before the Department of the Treasury pursuant to section 330 of title 31, United States Code, (B) any tax return preparer (as defined in section 7701(a)(36) of the Internal Revenue Code of 1986) with an identifying number (as described in section 6109(a)(4) of such Code), or (C) any qualified reporting agent, permit such representative, preparer, or agent, to the extent authorized by the taxpayer, to access the information described in paragraph (1) or transmit any information described in paragraph (2). (b) Availability for Viewing.--With respect to any return, document, notice, or letter described in paragraph (1) of subsection (a), such return, document, notice, or letter shall be made available for viewing by the taxpayer (or, pursuant to paragraph (3) of such subsection, any representative, tax return preparer, or qualified reporting agent authorized by the taxpayer) as soon as is practicable and within such periods as are established pursuant to regulations prescribed by the Secretary. (c) Access to Multiple Accounts by Representative, Preparer, or Agent.--For purposes of subsection (a)(3), the website or mobile application shall allow a representative, tax return preparer, or qualified reporting agent to be able to access information for multiple taxpayers who have provided permission under such subsection without any requirement to individually and separately access the account of each such taxpayer. (d) Applicable Period.-- (1) In general.--Subject to paragraph (2), for purposes of subsection (a)(1), the term ``applicable period'' means the preceding 6-year period. (2) Prospective application.--The term ``applicable period'' shall not include any years ending before the date of enactment of this Act. (e) Qualified Reporting Agent.-- (1) In general.--For purposes of this section, the term ``qualified reporting agent'' means a person-- (A) which is properly authorized as an agent to sign and file employment tax returns, make related payments and deposits, and perform such other acts on behalf of a taxpayer under procedures set forth by the Secretary, (B) which has met such requirements as may be established by the Secretary, and (C) for which authorization has not been revoked or suspended by the Secretary pursuant to procedures established by the Secretary. (2) Employment tax return.--For purposes of paragraph (1)(A), the term ``employment tax return'' means-- (A) any return required to be filed by an employer to report the obligations of the employer and its employees under section 3101, 3111, 3301, or 3402 of the Internal Revenue Code of 1986, and (B) such other returns as designated by the Secretary. (f) Preventing Unauthorized Disclosure of Return Information by Persons Designated by Taxpayers.--Not later than January 1 of the first calendar year beginning more than 18 months after the date of enactment of this Act, the Secretary shall-- (1) establish a program to investigate and address-- (A) any access, use, or disclosure of return information (as defined in section 6103(b) of the Internal Revenue Code of 1986) by any person which is in excess of the authorization permitted to such person pursuant to subsection (a)(3), and (B) any related misconduct, and (2) annually publish, on the public website of the Internal Revenue Service, the actions undertaken pursuant to the program described in paragraph (1), such as the number of complaints investigated, the number of persons whose access was revoked, and other relevant statistical data. (g) Focus Groups.--For purposes of subsection (a), prior to the date that the website or mobile application described in such subsection is made available, the Secretary shall conduct focus groups with taxpayers and tax professionals to ensure that any amounts appropriated or otherwise made available for such purposes are expended in an appropriate manner.

SEC. 106. AUTOMATION OF REFUND OFFSET BYPASS.

(a) In General.--Section 6402(a) is amended-- (1) by striking ``In the case'' and inserting the following: ``(1) Authority.--Except as provided in paragraph (2), in the case'', and (2) by adding at the end the following new paragraphs: ``(2) Special rule for certain individuals.--In the case of an overpayment with respect to any taxable year for which a credit is allowed to an applicable taxpayer under section 32, the Secretary shall, subject to subsections (c), (d), (e), and (f), refund such overpayment in an amount not to exceed the amount of the credit allowed under such section for such taxable year. ``(3) Applicable taxpayer.--For purposes of paragraph (2), the term `applicable taxpayer' means a taxpayer who was classified by the Secretary as currently not collectible (within the meaning of section 6343(e)) prior to the date on which the refund was requested by the taxpayer.''. (b) Effective Date.--The amendments made by this section shall apply to offsets made after the date which is 12 months after the date of enactment of this Act.

SEC. 107. INSTALLMENT AGREEMENT FEES ELIMINATED FOR CERTAIN INDIVIDUALS.

(a) In General.--Section 6159(f) is amended by striking paragraph (2) and inserting the following: ``(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.

SEC. 108. INDIVIDUALS FACING ECONOMIC HARDSHIPS INFORMED OF COLLECTION ALTERNATIVES.

(a) In General.--Not later than 12 months after the date of enactment of this Act, the Secretary shall-- (1) establish a program to identify taxpayers who-- (A) are reasonably likely to be experiencing an economic hardship, and (B) have an unpaid tax liability, and (2) in the case of any taxpayer described in paragraph (1) who requests to enter into an agreement described in section 6159(a) of the Internal Revenue Code of 1986, provide such taxpayer with information regarding other options which the Internal Revenue Service makes available to taxpayers who have an unpaid tax liability and are experiencing an economic hardship, including-- (A) an agreement described in such section for partial collection of a tax liability, (B) an offer-in-compromise (as described in section 7122 of such Code), and (C) classification as currently not collectible (within the meaning of section 6343(e) of such Code). (b) Economic Hardship.--For purposes of this section, in determining whether a taxpayer is reasonably likely to be experiencing an economic hardship, such determination shall be made in the same manner as determined under section 6343(a)(1)(D) of the Internal Revenue Code of 1986 based on-- (1) the most recent income and asset data which the Secretary has received from a return or a report from, or with respect to, such taxpayer, and (2) the schedules described in section 7122(d)(2)(A) of such Code. (c) Report.--Not later than 2 years after the date of enactment of this Act, the Secretary, in consultation with the National Taxpayer Advocate, shall submit a report to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate regarding-- (1) the accuracy of the Internal Revenue Service with respect to identifying taxpayers who are reasonably likely to be experiencing an economic hardship under subsection (a)(1), (2) whether such identification procedures may be appropriately applied for other purposes, and (3)(A) the number of taxpayers with an unpaid tax liability who were identified as reasonably likely to be experiencing an economic hardship under subsection (a)(1), (B) the options described in subsection (a)(2) that were provided to such taxpayers, and (C) the status of the tax liabilities of such taxpayers.

SEC. 109. QUARTERLY NOTICES TO CERTAIN TAXPAYERS WITH DELINQUENCIES.

(a) In General.--Section 7524 is amended-- (1) in the heading, by striking ``annual notice'' and inserting ``notice'', (2) by striking ``Not less often than annually'' and inserting the following: ``(a) In General.--Except as provided in subsection (c), not less often than quarterly'', and (3) by adding at the end the following: ``(b) Information on Penalties and Interest.--The notice described in subsection (a) shall include-- ``(1) an estimate of the amount of penalties and interest that may accrue if the delinquent tax debt is not fully paid within the period remaining under section 6502(a), and ``(2) programs and services that can provide assistance to the taxpayer. ``(c) Exception.--The requirement under subsection (a) shall not apply-- ``(1) during any period in which an agreement described in section 6159(a) or an accepted offer-in-compromise (as described in section 7122) is in effect, or ``(2) in the case of a taxpayer for which the Secretary has determined that the tax is not collectible (within the meaning of section 6343(e)).''. (b) Conforming Amendment.--The table of sections for chapter 77 is amended by striking the item relating to section 7524 and inserting the following new item:

``Sec. 7524. Notice of tax delinquency.''. (c) Effective Date.--The amendments made by this section shall take effect on the date which is 24 months after the date of enactment of this Act.

SEC. 110. LOW-INCOME TAXPAYER CLINIC FUNDING UNLOCKED.

(a) Matching Funds.--Paragraph (5) of section 7526(c) is amended to read as follows: ``(5) Requirement of matching funds.-- ``(A) In general.--With respect to any grant provided to a low-income taxpayer clinic under this section, such clinic shall provide matching funds equal to the applicable percentage of the amount of such grant. ``(B) Matching funds.-- ``(i) In general.--For purposes of this paragraph, the term `matching funds' may include-- ``(I) the salary (including fringe benefits) of individuals performing services for the low-income taxpayer clinic, and ``(II) the cost of equipment used in the low-income taxpayer clinic. ``(ii) Exclusion.--For purposes of this paragraph, the term `matching funds' shall not include any indirect expenses, such as general overhead of the institution sponsoring the low- income taxpayer clinic. ``(C) Applicable percentage.--For purposes of subparagraph (A), the applicable percentage shall be 100 percent, except that the Secretary may establish a lower percentage (not below 25 percent) if the Secretary determines that such percentage would expand the coverage of the low-income taxpayer clinic to additional taxpayers.''. (b) Technical Amendments.--Section 7526(c), as amended by subsection (a), is further amended-- (1) by striking paragraphs (1) and (2), and (2) by redesignating paragraphs (3) through (6) as paragraphs (1) through (4). (c) Effective Date.--The amendments made by this section shall apply to calendar years beginning after the date of enactment of this Act.

SEC. 111. CHIEF COUNSEL REVIEWS OF OFFERS-IN-COMPROMISE STREAMLINED.

(a) In General.--Section 7122(b) is amended by striking ``in any case'' and all that follows through ``his delegate'' and inserting ``in any case which the Secretary determines presents a significant legal issue, there shall be placed on file in the office of the Secretary the opinion of the General Counsel for the Department of the Treasury, or the Counsel's delegate''. (b) Conforming Amendments.--Section 7122(b) is amended by striking the second and third sentences. (c) Effective Date.--The amendments made by this section shall apply to offers-in-compromise submitted or pending on or after the date of the enactment of this Act.

SEC. 112. MODIFICATION OF PROCEDURAL REQUIREMENTS FOR PENALTIES AND DISALLOWANCE PERIODS.

(a) In General.--Section 6751(b) is amended-- (1) by striking paragraph (1) and inserting the following: ``(1) In general.--No penalty under this title shall be assessed, and no disallowance period shall take effect, unless-- ``(A) the decision (as defined by the Secretary in regulations) to apply such penalty or disallowance period, as applicable, is personally approved (in writing on an electronic form) by-- ``(i) the immediate supervisor of the individual making such decision, or ``(ii) the Internal Revenue Service Office of Servicewide Penalties (or any successor organization), and ``(B) the approval described in subparagraph (A) is obtained on or before the date any appealable notice is sent to the taxpayer regarding the application of such penalty or disallowance period.'', and (2) by adding at the end the following: ``(3) Appealable notice.--For purposes of this subsection, the term `appealable notice' means the first written notice issued to a taxpayer that provides the taxpayer an opportunity to-- ``(A) appeal the decision to the Internal Revenue Service Independent Office of Appeals, or ``(B) petition a Federal court for review of the decision.''. (b) Disallowance Period.--Section 6751 is amended by adding at the end the following new subsection: ``(d) Disallowance Period.-- ``(1) In general.--For purposes of this section, the term `disallowance period' means-- ``(A) with respect to any credit under section 24, the period determined under section 24(g)(1), ``(B) with respect to any credit under section 25A, the period determined under section 25A(b)(4)(A), and ``(C) with respect to any credit under section 32, the period determined under section 32(k)(1). ``(2) Approval required for disallowance period automatically calculated through electronic means.--With respect to the application of any disallowance period, subsection (b)(2)(B) shall not apply.''. (c) Effective Date.--The amendments made by this section shall apply to notices sent after the date which is 12 months after the date of the enactment of this Act. (d) Report.--Not later than 24 months after the date of enactment of this Act, and annually thereafter, the Secretary shall make publicly available a report regarding all penalties assessed by the Internal Revenue Service pursuant to the Internal Revenue Code of 1986 during the preceding calendar year, with all relevant data regarding such penalties to be collected and reported with respect to-- (1) every organizational unit of the Internal Revenue Service that has power to assess, abate, or otherwise enforce any penalty imposed by the Internal Revenue Service under the Internal Revenue Code of 1986, and (2) the progression of such penalties at each step of the determination, assessment, and review processes, as well as the final result with respect to such penalties.

SEC. 113. RETURN OF AMOUNTS COLLECTED BY IRS IN EXCESS OF ACCEPTED OFFER-IN-COMPROMISE AMOUNT.

(a) In General.--Section 7122 is amended by adding at the end the following: ``(h) Return Amounts Collected in Excess of Payment Amount of Accepted Offer-in-compromise.-- ``(1) In general.--Subject to paragraph (2), in the case of any taxpayer for which an offer-in-compromise has been accepted under this section, any proceeds collected with respect to the Federal income tax liability that is the subject of the accepted offer-in-compromise which are in excess of any remaining payments scheduled under such compromise shall be transferred to the taxpayer. ``(2) Exception.--Paragraph (1) shall not apply if-- ``(A) the taxpayer and the Secretary have specifically agreed otherwise, or ``(B) the Secretary has-- ``(i) determined that, under the terms of the compromise, such compromise is in default, and ``(ii) elected to terminate such compromise.''. (b) Authority to Release Levy and Return Property.--Section 6343 is amended-- (1) in subsection (a)(1)-- (A) in subparagraph (D), by striking ``or'' at the end, (B) in subparagraph (E), by striking the period at the end and inserting ``, or'', and (C) by adding at the end the following subparagraph: ``(F) subject to subsection (h)(2) of section 7122, an offer-in-compromise is accepted under such section with respect to the liability for which the levy was imposed.'', and (2) in subsection (d)(2)-- (A) in subparagraph (C), by striking ``or'' at the end, (B) in subparagraph (D), by striking the comma at the end and inserting ``, or'', and (C) by adding at the end the following subparagraph: ``(E) subject to subsection (h)(2) of section 7122, an offer-in-compromise is accepted under such section with respect to the liability for which the levy was imposed,''. (c) Effective Date.--The amendments made by this section shall apply to any compromise made under section 7122 of the Internal Revenue Code of 1986 which is accepted by the Secretary after the date of enactment of this Act.

SEC. 114. EXTENSION OF PERIOD FOR RETURN OF AMOUNTS SUBJECT TO WRONGFUL LEVY.

(a) In General.--Section 6343(b) is amended, in the flush text following paragraph (3), by striking ``the date of such levy'' and inserting ``the date that the Secretary received any such amount''. (b) Effective Date.--The amendments made by this section shall apply to any money levied upon or any amount of money received from the sale of property after the date which is 12 months after the date of enactment of this Act.

SEC. 115. REPORTS TO CONGRESS.

(a) Implementation.--Not later than the date which is 2 years after the date of enactment of this Act, the Secretary (following consultation with the National Taxpayer Advocate, the Treasury Inspector General for Tax Administration, and the Comptroller General of the United States) shall provide a report to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate regarding the actions taken by the Internal Revenue Service to implement this title and the amendments made by this title, including-- (1) an analysis of successes and challenges with respect to implementation of such title, and (2) any recommendations to Congress with respect to the implementation or administration of such title. (b) Fraud.-- (1) In general.--Not later than the date which is 12 months after the date of enactment of this Act, and annually thereafter, the Secretary shall provide a report to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate regarding efforts made by the Internal Revenue Service to identify, prevent, and resolve each type of tax fraud, including first-person fraud and stolen identity refund fraud. (2) Information included in report.--The report described in paragraph (1) shall include-- (A) a detailed description, timeline, and analysis of any efforts undertaken by the Internal Revenue Service and any of the other members of the Security Summit during the most recent tax filing season to address and prevent each type of tax fraud, including-- (i) any specific information or guidelines provided by the Internal Revenue Service to any of the other members of the Security Summit (and vice versa) with respect to tax fraud, including-- (I) any ``be on the lookout'' alerts or other warnings, (II) updated guidelines or restrictions, (III) potential threat analyses, (IV) specific data or analytics, and (V) any other actionable threat information, and (ii) any specific recommendations provided by the Internal Revenue Service to any of the other members of the Security Summit (and vice versa) with respect to identifying, preventing, and resolving tax fraud, including any potential improvements to data, analytics, information sharing, and collaboration between the Internal Revenue Service and other members of the Security Summit, (B) a detailed description and timeline of any interactions between the Internal Revenue Service and any provider of tax filing options which does not participate in the Security Summit, including-- (i) any specific information or guidelines provided by the Internal Revenue Service to such provider (and vice versa) with respect to each type of tax fraud, including any items described in subclauses (I) through (V) of subparagraph (A)(i), and (ii) any specific recommendations provided by the Internal Revenue Service to such provider (and vice versa) with respect to identifying, preventing, and resolving tax fraud, including any potential improvements to data, analytics, information sharing, and collaboration between the Internal Revenue Service and such provider, (C) with respect to the most recently completed tax filing season-- (i) with respect to each specific type or form of tax fraud that has been identified by the Internal Revenue Service, any relevant data and analysis regarding the amount of such fraud during such tax filing season, including detailed numerical data regarding such fraud in relation to each separate Federal tax return form (including any amended returns) and the manner in which such returns were filed, and (ii) the total dollar amount of fraudulent claims for refund-- (I) for which any disbursement was erroneously made, and (II) which were identified and disallowed prior to any disbursement being made. (3) Publicly available.--Data included in the report described in paragraph (1) shall be made available on the public website of the Internal Revenue Service, provided that such data is appropriately redacted by the Secretary. (c) Complexity Report.--For purposes of section 4022 of the Internal Revenue Service Restructuring and Reform Act of 1998 (26 U.S.C. 7801 note), the submission of the report required under section 7803(c)(2)(B) of the Internal Revenue Code of 1986 shall not satisfy the requirement under subsection (a) of section 4022 of such Act to conduct an analysis of the sources of complexity in administration of the Federal tax laws and report the results of such analysis. (d) Document Management to Avoid Duplicative Requests to Constituents.-- (1) In general.--Not later than one year after the date of the enactment of this Act, and annually thereafter for the following 5 years, the Secretary shall submit to the Committee on Finance of the Senate a report describing the systems and practices for tracking documents submitted to the Internal Revenue Service by taxpayers, Congressional offices, and authorized third-party representatives. (2) Matters included.--The report described in paragraph (1) shall include the following: (A) A description of how the Internal Revenue Service catalogues, tracks, and retains documents and communications, including procedures for internal document sharing and for avoiding lost documents and duplicative requests to taxpayers. (B) A description of the status and future plans for managing electronic and paper submissions through online accounts, new document submission tools, and paper-retention processes. (C) A discussion of any modernization efforts aimed at reducing duplicative document requests and any barriers the Internal Revenue Service has identified to implementing improvements.

TITLE II--AMERICAN CITIZENS ABROAD

SEC. 201. REPORT ON COMBINED TAX AND FOREIGN BANK AND FINANCIAL ACCOUNT REPORTING.

(a) Study.-- (1) In general.--The Secretary shall conduct a study on-- (A) combining and simplifying reporting required under section 5314 of title 31, United States Code and sections 6038, 6038A, 6038B, 6038C, 6038D, 6039F, 6046A, and 6048 of the Internal Revenue Code of 1986; and (B) eliminating duplicative requests for information from nonresident United States taxpayers. (2) Consultation.--The study conducted under paragraph (1) shall include input from the National Taxpayer Advocate and nonresident United States taxpayers. (b) Report.--Not later than 180 days after the date of enactment of this Act, the Secretary shall submit to Congress a report on the study conducted under subsection (a), which shall include any actions taken by the Secretary as a result of such study and any recommendations for legislative changes necessary to effectuate the goal described in subsection (a)(1).

SEC. 202. STUDY AND REPORTS ON SIMPLIFICATION.

(a) GAO Study and Report.-- (1) In general.--The Comptroller General of the United States shall conduct a study on the burdens of compliance with Federal tax laws applicable to individuals who are United States persons (as defined in section 7701(a)(30) of the Internal Revenue Code of 1986) living abroad. (2) Factors considered.--The study conducted under subsection (a) shall identify problems relating to compliance of Federal tax laws for such United States persons, including burdens specific to low-income and moderate-income individuals, related to-- (A) understanding and complying with United States tax obligations, including obligations with respect to-- (i) the duty to file returns and pay taxes while living abroad, including in the absence of tax treaties that otherwise eliminate double taxation of income; (ii) the filing (including through electronic means) of Federal tax returns and any reports required under section 5314 of title 31, United States Code, in a timely, accurate, and affordable manner, (iii) foreign retirement plans treated as passive foreign investment companies; and (iv) foreign currency gains; (B) receiving and responding to inquiries from the Internal Revenue Service and the Financial Crimes Enforcement Network about returns and reports described in subparagraph (A)(ii), and access to services of such agencies with respect to such returns and reports; (C) access to financial products and services abroad, including local retirement vehicles and bank accounts; (D) access to affordable tax preparation services for United States income tax obligations; and (E) compliance burdens that are disproportionate to the amount of tax owed. (3) Report.--Not later than 1 year after the date of the enactment of this Act, the Comptroller General shall submit to the Secretary of Treasury and to Congress, and make publicly available, a report on the study conducted under paragraph (1). (b) Treasury Report.--Not later than 1 year after the date on which the Comptroller General submits the report under subsection (a)(3), the Secretary of the Treasury shall submit to Congress a report that describes-- (1) actions taken by the Department of Treasury to address any problems identified by the Comptroller General in such report; and (2) any legislation necessary to address such problems.

SEC. 203. EXTENSION OF TIME FOR PERSONS OUTSIDE OF THE UNITED STATES TO REQUEST ABATEMENT OF MATH ERROR.

(a) In General.--Section 6213(b)(2)(A) is amended by inserting ``(120 days in the case of a notice addressed to a person outside the United States)'' after ``60 days''. (b) Effective Date.--The amendment made by this section shall apply to notices sent after the date that is 180 days after the date of the enactment of this Act.

SEC. 204. CLARIFICATION OF ASSESSMENT AUTHORITY; PRE-ASSESSMENT APPEALS OF FOREIGN INFORMATION RETURN PENALTIES.

(a) Treatment of Penalties as Taxes.--Section 6671(a) is amended-- (1) by striking ``The penalties and liabilities provided by this subchapter'' and inserting the following: ``(1) In general.--Any penalties provided by this title, including the penalties and liabilities provided by this subchapter,'', (2) by striking ``the penalties and liabilities provided by this subchapter.'' and inserting ``the penalties provided by this title, including the penalties and liabilities provided by this subchapter.'', and (3) by adding at the end the following new paragraph: ``(2) Exception.--Paragraph (1) shall not apply to any penalty not provided by this subchapter if such penalty is a penalty for which a civil or criminal action is prescribed as the method of collection or has been consistently treated by the Secretary before the date of the enactment of this paragraph as such a penalty.''. (b) Notice Requirement for Certain Penalties.-- (1) In general.--Subchapter C of chapter 68 is amended by adding at the end the following new section:

``SEC. 6752. PRELIMINARY NOTICE AND RIGHT OF REVIEW FOR COVERED PENALTIES.

``(a) Notice.-- ``(1) In general.--No covered penalty shall be assessed unless the Secretary provides a notice to the taxpayer in writing by mail to an address as determined under section 6212(b) that contains the following information: ``(A) The covered penalty proposed to be assessed. ``(B) The taxable years or periods involved. ``(C) The basis for the proposed penalty. ``(D) Information about the right of the taxpayer to request review as provided in subsection (b). ``(2) Timing of notice.--The mailing of the notice described in paragraph (1) shall precede any notice and demand of any covered penalty by at least 60 days (120 days in the case of a notice addressed to a taxpayer outside the United States). ``(b) Right to a Review.--Within 60 days (120 days in the case of a notice sent to a taxpayer outside the United States) of the mailing of the notice described in subsection (a), the taxpayer may request a review of the proposed penalty by the Internal Revenue Service Independent Office of Appeals. ``(c) Suspension of Assessment and Collection.-- ``(1) In general.--A covered penalty may not be assessed, demanded, or collected before-- ``(A) the expiration of the period provided under subsection (b), or ``(B) in any case in which the taxpayer requests a review under subsection (b), the date a final determination is issued in such review. ``(2) Statute of limitations.--If a notice described in subsection (a) with respect to any covered penalty is mailed before the expiration of the period provided by section 6501 for the assessment of such penalty (determined without regard to this paragraph), the running of such period shall be suspended for the period during which assessment is prohibited under this section and for 30 days thereafter. ``(d) Covered Penalty.--For purposes of this section, the term `covered penalty' means any penalty imposed under section 6038(b)(1), 6038A(d)(1), 6038B(c), 6038C(c), 6038D(d)(1), 6039F(c)(1)(B), or 6677. ``(e) Exception for Jeopardy.--This section shall not apply if the Secretary finds that the collection of the penalty is in jeopardy. ``(f) Regulations.--The Secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out this section, including regulations or other guidance relating to-- ``(1) procedures for issuing notices under subsection (a), and ``(2) establishing simplified reviews for cases in which the penalty amount at issue does not exceed a designated dollar threshold.''. (2) Clerical amendment.--The table of sections for subchapter C of chapter 68 is amended by adding at the end the following new item:

``Sec. 6752. Preliminary notice and right of review for covered penalties.''. (c) Interpretive Rules.-- (1) Taxpayer rights.--Nothing in the amendments made by this section shall be construed to create any limitation on the rights of a taxpayer-- (A) under subchapter C or D of chapter 64 of the Internal Revenue Code of 1986, or (B) to pursue refund litigation with respect to the assessment or imposition of any penalty imposed under such Code. (2) No inference.--Nothing in the amendments made by this section shall be construed to create any inference with respect to the treatment of any covered penalty (as defined in section 6752 of the Internal Revenue Code of 1986, as added by this section) before the date of the enactment of this Act.

SEC. 205. REPEAL OF DUE DATE REQUIREMENTS FOR CERTAIN INFORMATION RETURNS RELATING TO FOREIGN GIFTS AND TRUSTS.

(a) In General.--Section 2006(b) of the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 is amended by striking paragraphs (9) and (10). (b) Effective Date.--The amendment made by this section shall apply to returns for taxable years beginning after December 31, 2026.

TITLE III--JUDICIAL REVIEW

SEC. 301. AUTHORIZATION OF SUBPOENAS BEFORE HEARINGS TO FACILITATE SETTLEMENTS.

Section 7456(a) is amended to read as follows: ``(a) In General.-- ``(1) Administration of oaths.--For the efficient administration of the functions vested in the Tax Court or any division thereof, any judge or special trial judge, the clerk or the clerk's deputies, as such, or any other employee of the Tax Court designated in writing for the purpose by the chief judge, may administer oaths or affirmations. ``(2) Examination.--Any judge or special trial judge may examine parties or witnesses. ``(3) Subpoena authority.--Any judge or special trial judge may require, by subpoena ordered by the Tax Court or any division thereof and signed by the judge or special trial judge (or by the clerk of the Tax Court or by any other employee of the Tax Court when acting as deputy clerk), any of the following: ``(A) The attendance and testimony of parties or witnesses. ``(B) The production of books, papers, documents, electronically stored information, or tangible things from any place in the United States by any party or witness having custody or control thereof for purposes of discovery or for use of the things produced as evidence in accordance with the rules and orders of the Tax Court. Any such subpoena shall be issued and served, and compliance therewith shall be compelled, as provided in the rules and orders of the Tax Court. ``(4) Depositions.--Pursuant to rules and orders of the Court, the deposition of a witness may be taken before any designated individual competent to administer oaths under this title. Any deposition testimony shall be reduced to writing by the individual taking the deposition, or under such individual's direction, and shall be subscribed by the deponent.''.

SEC. 302. CLARIFICATION OF TAX COURT AUTHORITY TO ORDER RELIEF FROM A JUDGMENT OR ORDER.

Section 7481 is amended-- (1) by striking ``and (d),'' in subsection (a) and inserting ``(d), and (e),'' and (2) by adding at the end the following new subsection: ``(e) Relief From a Judgment or Order.-- ``(1) Corrections based on clerical mistakes; oversights and omissions.-- ``(A) In general.--The Tax Court may correct a clerical mistake, or a mistake arising from oversight or omission, whenever one is found in a judgment, order, or other part of the record. The Tax Court may do so on motion or on its own, with or without notice. ``(B) Appellate court leave required on appeal.-- After an appeal has been docketed in the appellate court, and while such appeal is pending, any such mistake may be corrected only with the appellate court's leave. ``(2) Grounds for relief from a final judgment or order.-- On motion and just terms, the Tax Court may relieve a party or its legal representative from a final judgment or order for any of the following reasons: ``(A) Mistake, inadvertence, surprise, or excusable neglect. ``(B) Newly discovered evidence that, with reasonable diligence, could not have been discovered in time to move for a new trial under rules prescribed by the Court and that would have a reasonable likelihood of changing the outcome. ``(C) Fraud (whether previously called intrinsic or extrinsic), misrepresentation, or misconduct by an opposing party. ``(D) The judgment is void. ``(E) Any other circumstance where justice so requires. ``(3) Timing and effect of the motion.-- ``(A) Timing.--A motion under paragraph (2)-- ``(i) must be made within a reasonable time, and ``(ii) in the case of a reason described in subparagraphs (A), (B), or (C), not later than 1 year after the entry of the judgment or order. ``(B) Effect on finality.--While pending, any such motion does not affect the judgment's finality or suspend its operation. ``(4) Other powers to grant relief.--This subsection shall not limit the Tax Court's power to set aside a judgment for fraud on the Tax Court. ``(5) Court of appeals jurisdiction.--If the Tax Court provides relief from a judgment or order that is otherwise final under this section, either or both parties may obtain review of such relief by filing a notice of appeal under this subchapter within 90 days of the Court's judgment or order directing such relief.''.

SEC. 303. AUTHORIZATION OF SPECIAL TRIAL JUDGES TO HEAR ADDITIONAL CASES AND ADDRESS CONTEMPT.

(a) Consent to Assignment.--Section 7443A(b) is amended by striking ``and'' at the end of paragraph (6), by redesignating paragraph (7) as paragraph (8), and by inserting after paragraph (6) the following new paragraph: ``(7) upon the consent of the parties, and pursuant to rules promulgated by the Tax Court, any proceeding not described in paragraphs (1) through (6), and''. (b) Authorizing Special Trial Judge.--Section 7443A(c) is amended by striking ``or (6)'' and inserting ``(6), or (7)''. (c) Contempt Authority.--Section 7443A is amended by adding at the end the following new subsection: ``(f) Incidental Powers.--A special trial judge appointed under this section shall have the independent power to punish for contempt of the authority of the Tax Court as provided in section 7456(c), except the sentence imposed by such a special trial judge for any contempt shall not exceed the penalties for a Class C misdemeanor as set forth in sections 3571(b)(6) and 3581(b)(8) of title 18, United States Code. This subsection shall not be construed to limit the authority of a special trial judge to order sanctions under any other statute or any rule of the Tax Court prescribed pursuant to section 7453.''. (d) Effective Date.--The amendments made by subsections (a) and (b) shall take effect on the date the United States Tax Court adopts rules implementing the consent procedures of section 7443A.

SEC. 304. DISQUALIFICATION OF JUDGES AND SPECIAL TRIAL JUDGES.

(a) In General.--Part II of subchapter C of chapter 76 is amended by adding at the end the following new section:

``SEC. 7467. DISQUALIFICATION OF JUDGE OR SPECIAL TRIAL JUDGE.

``Section 455 of title 28, United States Code, shall apply to judges, special trial judges, and proceedings of the Tax Court.''. (b) Clerical Amendment.--The table of sections for such part is amended by adding at the end the following new item:

``Sec. 7467. Disqualification of judge or special trial judge.''.

SEC. 305. NOTICE AND REVIEW WITH RESPECT TO MULTI-YEAR BANS ON CLAIMING CREDITS.

(a) Notice.-- (1) In general.--Section 6212(a) is amended-- (A) by striking ``If the'' and inserting the following: ``(1) Notice.--If the'', (B) by striking ``Such notice shall include a notice'' and inserting the following: ``(2) Matters included.--Such notice shall include-- ``(A) a notice'', (C) by striking period at the end of the second sentence and inserting ``, and'', and (D) by adding at the end the following new subparagraph: ``(B) in any case in which such deficiency for a taxable year is attributable to the denial of a credit under section 24, 25A, or 32, a statement-- ``(i) identifying the credit or credits which are denied and providing the grounds for each such denial, ``(ii) informing the taxpayer that, unless the denial is overturned on appeal, the taxpayer will not be able to claim such credit for any subsequent taxable year unless the taxpayer provides information required by the Secretary to demonstrate eligibility for the credit, and ``(iii) in any case in which the Secretary has made a determination to impose a disallowance period under section 24(g)(1), 25A(b)(4)(A), or 32(k)(1), providing the grounds for such disallowance period (and the length of the disallowance period unless overturned on appeal).''. (2) Effective date.--The amendments made by this subsection shall apply to notices mailed on or after the date that is 36 months after the date of enactment of this Act. (b) Authority of the Tax Court.-- (1) In general.--Section 6214 is amended by redesignating subsection (e) as subsection (f) and by inserting after subsection (d) the following new subsection: ``(e) Jurisdiction With Respect to Multi-Year Bans With Respect to Certain Credits.-- ``(1) In general.--The Tax Court shall have jurisdiction-- ``(A) to redetermine the imposition of any disallowance period with respect to any credit under section 24, 25A, or 32 for the taxable year in which such disallowance period was imposed if the deficiency relates to such taxable year, and ``(B) to determine whether any such disallowance period should be imposed if claim therefor is asserted by the Secretary in the answer or an amended answer filed in accordance with the rules of the Tax Court. ``(2) Disallowance period.--For purposes of this subsection, the term `disallowance period' has the meaning given such term under section 6751(d).''. (2) Effective date.--The amendments made by this subsection apply to petitions filed on or after the date of enactment of this Act. (3) Transition rule for review of previously imposed disallowance periods.-- (A) In general.--In the case of any deficiency which is attributable to an entry on the return claiming a credit under section 24, 25A, or 32 of the Internal Revenue Code of 1986 for a taxable year in a disallowance period described in subparagraph (B), the Tax Court shall have jurisdiction to redetermine whether the disallowance period was properly imposed. (B) Disallowance period described.--A disallowance period is described in this subparagraph if the notice of the deficiency under section 6212 of such Code for the taxable year with respect to which the determination to impose the disallowance period was made-- (i) did not include the grounds for such disallowance period, and (ii) was mailed before the date that is 36 months after the date of the enactment of this Act. (C) Disallowance period.--For purposes of this paragraph, the term ``disallowance period'' has the meaning given such term under section 6751(d) of the Internal Revenue Code of 1986 (as added by this Act). (D) Refunds.--Notwithstanding section 6512(b)(1) of the Internal Revenue Code of 1986, in the case of a petition with respect to a disallowance period described in subparagraph (B), the Tax Court shall have jurisdiction to determine the amount of an overpayment for any taxable year in the disallowance period, and such amount shall, notwithstanding section 6511, when the decision of the Tax Court has become final, be credited or refunded to the taxpayer. If a notice of appeal in respect of the decision of the Tax Court is filed under section 7483 of such Code, the Secretary is authorized to refund or credit the overpayment determined by the Tax Court to the extent the overpayment is not contested on appeal. (c) Burden of Production.-- (1) In general.--Section 7491(c) is amended-- (A) by striking ``Notwithstanding'' and inserting the following: ``(1) In general.--Notwithstanding'', (B) by striking ``with respect to the liability'' and inserting ``with respect to-- ``(A) the liability'', (C) by striking the period after ``title'' and inserting ``, and'', (D) by adding at the end the following new subparagraph: ``(B) the application of any disallowance period (as defined in section 6751(d)) to any individual.'', and (E) by adding at the end

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