HR 6506 · Taxpayer Due Process Enhancement Act
Received in the Senate and Read twice and referred to the Committee on Finance.
- Introduced
- Dec 9, 2025
- Latest action
- May 20, 2026
- Sponsor
- Rep. Nathaniel Moran [R-TX-1]
- Policy area
- Taxation
- Cosponsors
- 1
Summary
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.
Recent actions
- Jan 7, 2026 Placed on the Union Calendar, Calendar No. 373.
- Jan 7, 2026 Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.
- Jan 7, 2026 Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.
- Dec 10, 2025 Ordered to be Reported in the Nature of a Substitute (Amended) by the Yeas and Nays: 41 - 0.
- Dec 10, 2025 Committee Consideration and Mark-up Session Held
- Dec 9, 2025 Referred to the House Committee on Ways and Means.
- Dec 9, 2025 Introduced in House
- Dec 9, 2025 Introduced in House
Votes
No recorded votes are available for this bill.