Protecting Innocent Taxpayers from Endless Assessments Act
Official title: A bill to amend the Internal Revenue Code of 1986 to clarify that the exception to the general statute of limitations for fraudulent returns applies only when … Show full official titleShow less
Official title: A bill to amend the Internal Revenue Code of 1986 to clarify that the exception to the general statute of limitations for fraudulent returns applies only when a taxpayer seeks to evade their tax obligations.
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Read twice and referred to the Committee on Finance.
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.
- Introduced in Senate Formatted Text PDF Formatted XML
Cite this page
U.S. Congress. (2026). S. 4964: Protecting Innocent Taxpayers from Endless Assessments Act. 119th Congress. Open America. https://openamerica.io/bill/119-S-4964/
"S. 4964: Protecting Innocent Taxpayers from Endless Assessments Act." 119th Congress, 2026, Open America, https://openamerica.io/bill/119-S-4964/.
S. 4964, 119th Cong. (2026), https://openamerica.io/bill/119-S-4964/.
[S. 4964: Protecting Innocent Taxpayers from Endless Assessments Act](https://openamerica.io/bill/119-S-4964/)