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HR 6506 119th Congress House Taxation Income tax credits Jurisdiction and venue Specialized courts Tax administration and collection, taxpayers

Taxpayer Due Process Enhancement Act

Introduced: December 9, 2025 Introduced by: Moran, Nathaniel Republican · Texas See on congress.gov
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 Everywhere this bill has been 13 steps
Introduced
In committee
Reported out
Passed House
Passed Senate
To President
Became law
May 20, 2026
Received in the Senate and Read twice and referred to the Committee on Finance.
May 19, 2026 · 3:36 PM EDT
On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564)
May 19, 2026 · 3:36 PM EDT
Passed/agreed to in House: On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564)
May 19, 2026 · 3:22 PM EDT
Mr. Smith (MO) moved to suspend the rules and pass the bill, as amended.
May 19, 2026 · 3:36 PM EDT
Motion to reconsider laid on the table Agreed to without objection.
May 19, 2026 · 3:22 PM EDT
Considered under suspension of the rules. (consideration: CR H3564-3567)
May 19, 2026 · 3:22 PM EDT
DEBATE - The House proceeded with forty minutes of debate on H.R. 6506.
Jan 7, 2026
Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.
Jan 7, 2026
Placed on the Union Calendar, Calendar No. 373.
Dec 10, 2025
Committee Consideration and Mark-up Session Held
Dec 10, 2025
Ordered to be Reported in the Nature of a Substitute (Amended) by the Yeas and Nays: 41 - 0.
Dec 9, 2025
Referred to the House Committee on Ways and Means.
Dec 9, 2025
Introduced in House
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 Plain-English summary Congressional Research Service

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.
What's happening now May 20, 2026

Received in the Senate and Read twice and referred to the Committee on Finance.

 Bill text 4 versions

Source documents hosted by congress.gov.

 Committees of jurisdiction 2
 Lobbying activity 4

Registered lobbyists who named this bill in their disclosure filings. Source: federal Lobbying Disclosure Act filings.

 Cosponsors 1
All 1 Democratic 1
D
Sewell, Terri A.
Alabama · Dec 9, 2025
Cite this page click to expand
APA
U.S. Congress. (2026). H.R. 6506: Taxpayer Due Process Enhancement Act. 119th Congress. Open America. https://openamerica.io/bill/119-HR-6506/
MLA
"H.R. 6506: Taxpayer Due Process Enhancement Act." 119th Congress, 2026, Open America, https://openamerica.io/bill/119-HR-6506/.
Bluebook (legal)
H.R. 6506, 119th Cong. (2026), https://openamerica.io/bill/119-HR-6506/.
Markdown link
[H.R. 6506: Taxpayer Due Process Enhancement Act](https://openamerica.io/bill/119-HR-6506/)
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