119:hr:6506 — Taxpayer Due Process Enhancement Act

Sponsor

Introduced by

Nathaniel Moran

R Republican · House · TX-01 R+25

Latest action

Placed on the Union Calendar, Calendar No. 373.

Action timeline

Every recorded action on this bill, newest first. Stage badges color-code the legislative path.

Jan 07, 2026

committee Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.

Ways and Means Committee

Jan 07, 2026

other Placed on the Union Calendar, Calendar No. 373.

Dec 10, 2025

committee Committee Consideration and Mark-up Session Held

Ways and Means Committee

Dec 10, 2025

committee Ordered to be Reported in the Nature of a Substitute (Amended) by the Yeas and Nays: 41 - 0.

Ways and Means Committee

Dec 09, 2025

introduced Introduced in House

Text versions

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Jan 07, 2026 Reported in House

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Dec 09, 2025 Introduced in House

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CRS summaries

Plain-English summaries written by the Congressional Research Service — neutral, nonpartisan staff who summarize bills as they advance through stages. The authoritative description of what each version of the bill does.

07 Reported to House Jan 07, 2026

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.

via Congressional Research Service · published through congress.gov

Changelog

ⓘ

How a bill moves through Congress. Each stage produces a new official text. The diff between them shows what changed at that step.

`ih` / `is` — Introduced in House / Senate. First filed version.

`rfh` / `rfs` — Referred to a committee for review.

`rh` / `rs` — Reported back by the committee to the floor (often with amendments — this is where most language changes happen).

`pcs` / `pch` — Placed on Calendar for floor consideration.

`eh` / `es` — Engrossed. Passed by the originating chamber. Text is now what was actually voted on.

`rdh` / `rds` — Received by the other chamber.

`eah` / `eas` — Engrossed Amendment. The other chamber passed an amended version.

`ath` / `ats` — Agreed to. Both chambers settled on the same text.

`enr` — Enrolled. Final reconciled text, sent to the President.

`pl` — Public Law. Signed by the President. It's now law.

`pp` — Public Print. Official printing post-enactment.

Most bills die before `eh`/`es`. Going from `pcs` → `enr` is the full path through both chambers.

Line-level diff between text versions of this bill — what actually changed at each legislative stage.

+43 −6 18 unchanged

--- Introduced (House)

+++ Reported (House)

@@ -1,11 +1,14 @@

[From the U.S. Government Publishing Office]

-[H.R. 6506 Introduced in House (IH)]

+[H.R. 6506 Reported in House (RH)]

<DOC>

+Union Calendar No. 373

119th CONGRESS

-1st Session

+2d Session

H. R. 6506

+

+[Report No. 119-428]

To amend the Internal Revenue Code of 1986 to suspend the period of

limitations on filing a claim for credit or refund during collection

@@ -21,6 +24,15 @@

Mr. Moran (for himself and Ms. Sewell) introduced the following bill;

which was referred to the Committee on Ways and Means

+

+January 7, 2026

+

+Reported with an amendment, committed to the Committee of the Whole

+House on the State of the Union, and ordered to be printed

+[Strike out all after the enacting clause and insert the part printed

+in italic]

+[For text of introduced bill, see copy of bill as introduced on

+December 9, 2025]

_______________________________________________________________________

@@ -130,7 +142,32 @@

the Secretary abandons the collection action or

proposed collection action at issue in such

determination.''.

-(b) Effective Date.--The amendment made by this subsection shall

-apply with respect to petitions filed after the date of the enactment

-of this Act.

-<all>

+(b) Effective Date.--The amendment made by this section shall apply

+with respect to petitions filed after the date of the enactment of this

+Act.

+Union Calendar No. 373

+

+119th CONGRESS

+

+2d Session

+

+H. R. 6506

+

+[Report No. 119-428]

+

+_______________________________________________________________________

+

+A BILL

+

+To amend the Internal Revenue Code of 1986 to suspend the period of

+limitations on filing a claim for credit or refund during collection

+action proceedings, to prohibit the crediting of overpayments against

+disputed tax liability during such proceedings, and to expand the

+jurisdiction of the Tax Court.

+

+_______________________________________________________________________

+

+January 7, 2026

+

+Reported with an amendment, committed to the Committee of the Whole

+House on the State of the Union, and ordered to be printed

Lobbying activity

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CHAMBER OF COMMERCE OF THE U.S.A.

TAX

1

filings · 2025 Q4

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Cosponsors (1)

Members who signed on to support this bill.

Sewell D