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S 2851 110th Congress Senate

A bill to amend the Internal Revenue Code of 1986 to modify the penalty on the understatement of taxpayer's liability by tax return preparers.

Introduced: July 31, 2008 See on congress.gov
Taxation Evidence (Law)Government Operations and PoliticsGovernment paperworkIncome tax
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LawTax evasionTax penaltiesTax preparersTax returnsTax shelters
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This bill died when the 110th Congress ended
It never became law before the 110th Congress (2007–2008) adjourned, and bills don't carry over to the next Congress. It would have to be reintroduced. You can still save it for reference, but it won't receive updates.
 Everywhere this bill has been 2 steps
Introduced
In committee
Reported out
Passed House
Passed Senate
To President
Became law
Apr 14, 2008
Read twice and referred to the Committee on Finance.
Apr 14, 2008
Introduced in Senate
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 Latest action April 14, 2008

Read twice and referred to the Committee on Finance.

 Plain-English summary Congressional Research Service

Amends the Internal Revenue Code to modify the standards for imposing penalties on tax return preparers for understatements of tax to require: (1) substantial authority for a position with respect to an item on a tax return if such position was not disclosed with the return; and (2) a reasonable basis for a position which was disclosed with the return.

Requires tax return preparers to have a reasonable belief that a position with respect to a tax shelter or a reportable transaction (a transaction having a potential for tax avoidance or evasion) will more likely than not be sustained on its merits.

 Related & companion bills 2
  • HR 5719 Related bill Taxpayer Assistance and Simplification Act of 2008
  • HR 4318 Identical bill To amend the Internal Revenue Code of 1986 to modify the penalty on the understatement of taxpayer's liability by tax r…
 Bill text 1 version

Source documents hosted by congress.gov.

 Committees of jurisdiction 1
 Cosponsors 3
All 3 Democratic 1
Isakson, Johnny
· Jul 31, 2008
Vitter, David
· Jul 28, 2008
 D
Cantwell, Maria
Washington · Jul 10, 2008
Cite this page click to expand
APA
U.S. Congress. (2026). S. 2851: A bill to amend the Internal Revenue Code of 1986 to modify the penalty on the understatement of taxpayer's liability by tax return preparers.. 110th Congress. Open America. https://openamerica.io/bill/110-S-2851/
MLA
"S. 2851: A bill to amend the Internal Revenue Code of 1986 to modify the penalty on the understatement of taxpayer's liability by tax return preparers.." 110th Congress, 2026, Open America, https://openamerica.io/bill/110-S-2851/.
Bluebook (legal)
S. 2851, 110th Cong. (2026), https://openamerica.io/bill/110-S-2851/.
Markdown link
[S. 2851: A bill to amend the Internal Revenue Code of 1986 to modify the penalty on the understatement of taxpayer's liability by tax return preparers.](https://openamerica.io/bill/110-S-2851/)
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