Both sides have signed this (Bill Ranking)
H.R. 6506 · 119th Congress (2025-2026)
2 members · Left 1 · Center 0 · Right 1 (Bill Ranking)
| Sponsor | Rep. Moran, Nathaniel (R-TX) (Introduced 12/09/2025) |
|---|---|
| Sponsor Voting Record | Right · DW-NOMINATE +0.59 · measured from every roll-call vote this member has cast (voteview.com) (Sponsor Ranking) |
| Support |
LLLCLRR support across the spectrum: 2 members signed on (Bill Ranking) this bill: sponsor + current cosponsors, each once |
| Committees | Senate - Finance Committee; House - Ways and Means Committee; House - Ways and Means Committee; House - Ways and Means Committee |
| Latest Action | 05/20/2026 Received in the Senate and Read twice and referred to the Committee on Finance. |
| Roll Call Votes | There have been no roll call votes |
| Source | view on congress.gov → |
Reported to House (01/07/2026)
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
119 HR 6506 EH: Taxpayer Due Process Enhancement Act U.S. House of Representatives text/xml EN Pursuant to Title 17 Section 105 of the United States Code, this file is not subject to copyright protection and is in the public domain. IB 119th CONGRESS2d Session H. R. 6506
IN THE HOUSE OF REPRESENTATIVES AN ACT 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.
1.Short titleThis Act may be cited as the Taxpayer Due Process Enhancement Act.
2.Suspension of period of limitations on filing a claim for credit or refund during collection action proceedings (a)In generalSection 6330(e)(1) of the Internal Revenue Code of 1986 is amended by inserting subsection (a), (b), or (c) of section 6511 (relating to limitations on credit or refund), after section 6502 (relating to collection after assessment),. (b)Period of limitations on filing a claim for credit or refundSection 6330(e) of such Code is amended by adding at the end the following new paragraph: (3)Period of limitations on filing a claim for credit or refundIn the case of the running of any period of limitations under subsection (a), (b), or (c) of section 6511 with respect to the filing of any claim for credit or refund, paragraph (1)— (A)shall apply only to the extent that such credit or refund relates to an underlying tax liability properly disputed at the hearing requested under this section, and (B)shall not result in a suspension of the running of such period of limitations after any date on which a lapse of a deadline, a court filing, or a court order establishes that the taxpayer has forfeited or otherwise lost the right to pursue such dispute.. (c)Cross referenceSection 6511(i) of such Code is amended by adding at the end the following new paragraph: (8)For limitations in case of collection action proceedings, see section 6330(e).. (d)Effective dateThe amendments made by this section shall apply to the running of any period of limitations if such period (determined without regard to the amendments made by this section) ends on or after the date of the enactment of this Act.
3.Prohibition on crediting of overpayments against disputed tax liability during collection action proceedings (a)In generalSection 6402 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection: (o)Prohibition on crediting of overpayments against disputed tax liability during collection action proceedingsIf a hearing is properly requested under section 6320(a)(3)(B) or 6330(a)(3)(B), and an underlying tax liability referred to in section 6330(c)(2)(B) is properly disputed at such hearing, such tax liability shall not, except with the consent of the taxpayer, be taken into account under subsection (a) for the period during which the period of limitations for filing a claim for credit or refund relating to such tax liability is suspended by reason of section 6330(e).. (b)Clarification of application of certain levy hearing rules to lien hearingsSection 6330(c)(2)(A) of such Code is amended by striking unpaid tax or the proposed levy and inserting unpaid tax, collection action, or proposed collection action. (c)Effective dates (1)In generalThe amendment made by subsection (a) shall apply with respect to any period described in section 6402(o) of the Internal Revenue Code of 1986 (as added by this section) if any portion of such period is after the date of the enactment of this Act. (2)Clarification of application of certain levy hearing rules to lien hearingsThe amendment made by subsection (b) shall take effect on the date of the enactment of this Act.
4.Expansion of jurisdiction of Tax Court (a)In generalSection 6330(d)(1) of the Internal Revenue Code of 1986 is amended to read as follows: (1)Petition for review by Tax Court (A)In generalIn the case of a determination under this section, the person may, within 30 days of such determination, petition the Tax Court for review of— (i)such determination, and (ii)any underlying tax liability referred to in subsection (c)(2)(B) which is properly disputed at the hearing in which such determination is made. (B)Jurisdiction of Tax CourtUpon the filing of a petition, the Tax Court shall have jurisdiction with respect to— (i)the determination referred to in subparagraph (A)(i), (ii)any underlying tax liability referred to in subparagraph (A)(ii), and (iii)any equitable tolling of the 30-day deadline referred to in subparagraph (A). (C)Retention of jurisdictionUpon a determination being made under this section, subparagraphs (A) and (B) shall apply whether or not the Secretary abandons the collection action or proposed collection action at issue in such determination.. (b)Effective dateThe amendment made by this section shall apply with respect to petitions filed after the date of the enactment of this Act. Passed the House of Representatives May 19, 2026.Kevin F. McCumber,Clerk.
119 HR 6506 IH: Taxpayer Due Process Enhancement Act U.S. House of Representatives 2025-12-09 text/xml EN Pursuant to Title 17 Section 105 of the United States Code, this file is not subject to copyright protection and is in the public domain. I119th CONGRESS1st SessionH. R. 6506IN THE HOUSE OF REPRESENTATIVESDecember 9, 2025Mr. Moran (for himself and Ms. Sewell) introduced the following bill; which was referred to the Committee on Ways and MeansA BILLTo 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.
1.Short title This Act may be cited as the Taxpayer Due Process Enhancement Act.
2.Suspension of period of limitations on filing a claim for credit or refund during collection action proceedings (a)In generalSection 6330(e)(1) of the Internal Revenue Code of 1986 is amended by inserting subsection (a), (b), or (c) of section 6511 (relating to limitations on credit or refund), after section 6502 (relating to collection after assessment),. (b)Period of limitations on filing a claim for credit or refundSection 6330(e) of such Code is amended by adding at the end the following new paragraph: (3)Period of limitations on filing a claim for credit or refundIn the case of the running of any period of limitations under subsection (a), (b), or (c) of section 6511 with respect to the filing of any claim for credit or refund, paragraph (1)— (A)shall apply only to the extent that such credit or refund relates to an underlying tax liability properly disputed at the hearing requested under this section, and (B)shall not result in a suspension of the running of such period of limitations after any date on which a lapse of a deadline, a court filing, or a court order establishes that the taxpayer has forfeited or otherwise lost the right to pursue such dispute.. (c)Cross referenceSection 6511(i) of such Code is amended by adding at the end the following new paragraph: (8)For limitations in case of collection action proceedings, see section 6330(e).. (d)Effective dateThe amendments made by this section shall apply to the running of any period of limitations if such period (determined without regard to the amendments made by this section) ends on or after the date of the enactment of this Act.
3.Prohibition on crediting of overpayments against disputed tax liability during collection action proceedings (a)In generalSection 6402 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection: (o)Prohibition on crediting of overpayments against disputed tax liability during collection action proceedingsIf a hearing is properly requested under section 6320(a)(3)(B) or 6330(a)(3)(B), and an underlying tax liability referred to in section 6330(c)(2)(B) is properly disputed at such hearing, such tax liability shall not, except with the consent of the taxpayer, be taken into account under subsection (a) for the period during which the period of limitations for filing a claim for credit or refund relating to such tax liability is suspended by reason of section 6330(e).. (b)Clarification of application of certain levy hearing rules to lien hearingsSection 6330(c)(2)(A) of such Code is amended by striking unpaid tax or the proposed levy and inserting unpaid tax, collection action, or proposed collection action. (c)Effective dates (1)In generalThe amendment made by subsection (a) shall apply with respect to any period described in section 6402(o) of the Internal Revenue Code of 1986 (as added by this section) if any portion of such period is after the date of the enactment of this Act. (2)Clarification of application of certain levy hearing rules to lien hearingsThe amendment made by subsection (b) shall take effect on the date of the enactment of this Act.
4.Expansion of jurisdiction of Tax Court (a)In generalSection 6330(d)(1) of the Internal Revenue Code of 1986 is amended to read as follows: (1)Petition for review by Tax Court (A)In generalIn the case of a determination under this section, the person may, within 30 days of such determination, petition the Tax Court for review of— (i)such determination, and (ii)any underlying tax liability referred to in subsection (c)(2)(B) which is properly disputed at the hearing in which such determination is made. (B)Jurisdiction of Tax CourtUpon the filing of a petition, the Tax Court shall have jurisdiction with respect to— (i)the determination referred to in subparagraph (A)(i), (ii)any underlying tax liability referred to in subparagraph (A)(ii), and (iii)any equitable tolling of the 30-day deadline referred to in subparagraph (A). (C)Retention of jurisdictionUpon a determination being made under this section, subparagraphs (A) and (B) shall apply whether or not the Secretary abandons the collection action or proposed collection action at issue in such determination.. (b)Effective dateThe amendment made by this subsection shall apply with respect to petitions filed after the date of the enactment of this Act.
119 HR 6506 : Taxpayer Due Process Enhancement Act U.S. House of Representatives 2026-05-20 text/xml EN Pursuant to Title 17 Section 105 of the United States Code, this file is not subject to copyright protection and is in the public domain. IIB119th CONGRESS2d SessionH. R. 6506IN THE SENATE OF THE UNITED STATESMay 20, 2026Received; read twice and referred to the Committee on FinanceAN ACTTo 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.1.Short titleThis Act may be cited as the Taxpayer Due Process Enhancement Act.2.Suspension of period of limitations on filing a claim for credit or refund during collection action proceedings(a)In generalSection 6330(e)(1) of the Internal Revenue Code of 1986 is amended by inserting subsection (a), (b), or (c) of section 6511 (relating to limitations on credit or refund), after section 6502 (relating to collection after assessment),.(b)Period of limitations on filing a claim for credit or refundSection 6330(e) of such Code is amended by adding at the end the following new paragraph:(3)Period of limitations on filing a claim for credit or refundIn the case of the running of any period of limitations under subsection (a), (b), or (c) of section 6511 with respect to the filing of any claim for credit or refund, paragraph (1)—(A)shall apply only to the extent that such credit or refund relates to an underlying tax liability properly disputed at the hearing requested under this section, and(B)shall not result in a suspension of the running of such period of limitations after any date on which a lapse of a deadline, a court filing, or a court order establishes that the taxpayer has forfeited or otherwise lost the right to pursue such dispute..(c)Cross referenceSection 6511(i) of such Code is amended by adding at the end the following new paragraph:(8)For limitations in case of collection action proceedings, see section 6330(e)..(d)Effective dateThe amendments made by this section shall apply to the running of any period of limitations if such period (determined without regard to the amendments made by this section) ends on or after the date of the enactment of this Act.3.Prohibition on crediting of overpayments against disputed tax liability during collection action proceedings(a)In generalSection 6402 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection:(o)Prohibition on crediting of overpayments against disputed tax liability during collection action proceedingsIf a hearing is properly requested under section 6320(a)(3)(B) or 6330(a)(3)(B), and an underlying tax liability referred to in section 6330(c)(2)(B) is properly disputed at such hearing, such tax liability shall not, except with the consent of the taxpayer, be taken into account under subsection (a) for the period during which the period of limitations for filing a claim for credit or refund relating to such tax liability is suspended by reason of section 6330(e)..(b)Clarification of application of certain levy hearing rules to lien hearingsSection 6330(c)(2)(A) of such Code is amended by striking unpaid tax or the proposed levy and inserting unpaid tax, collection action, or proposed collection action.(c)Effective dates(1)In generalThe amendment made by subsection (a) shall apply with respect to any period described in section 6402(o) of the Internal Revenue Code of 1986 (as added by this section) if any portion of such period is after the date of the enactment of this Act.(2)Clarification of application of certain levy hearing rules to lien hearingsThe amendment made by subsection (b) shall take effect on the date of the enactment of this Act.4.Expansion of jurisdiction of Tax Court(a)In generalSection 6330(d)(1) of the Internal Revenue Code of 1986 is amended to read as follows:(1)Petition for review by Tax Court(A)In generalIn the case of a determination under this section, the person may, within 30 days of such determination, petition the Tax Court for review of—(i)such determination, and(ii)any underlying tax liability referred to in subsection (c)(2)(B) which is properly disputed at the hearing in which such determination is made.(B)Jurisdiction of Tax CourtUpon the filing of a petition, the Tax Court shall have jurisdiction with respect to—(i)the determination referred to in subparagraph (A)(i),(ii)any underlying tax liability referred to in subparagraph (A)(ii), and(iii)any equitable tolling of the 30-day deadline referred to in subparagraph (A).(C)Retention of jurisdictionUpon a determination being made under this section, subparagraphs (A) and (B) shall apply whether or not the Secretary abandons the collection action or proposed collection action at issue in such determination..(b)Effective dateThe amendment made by this section shall apply with respect to petitions filed after the date of the enactment of this Act.Passed the House of Representatives May 19, 2026.Kevin F. McCumber,Clerk.
119 HR 6506 RH: Taxpayer Due Process Enhancement Act U.S. House of Representatives 2026-01-07 text/xml EN Pursuant to Title 17 Section 105 of the United States Code, this file is not subject to copyright protection and is in the public domain. IBUnion Calendar No. 373119th CONGRESS2d SessionH. R. 6506[Report No. 119–428]IN THE HOUSE OF REPRESENTATIVESDecember 9, 2025Mr. Moran (for himself and Ms. Sewell) introduced the following bill; which was referred to the Committee on Ways and MeansJanuary 7, 2026Reported with an amendment, committed to the Committee of the Whole House on the State of the Union, and ordered to be printedStrike out all after the enacting clause and insert the part printed in italicFor text of introduced bill, see copy of bill as introduced on December 9, 2025A BILLTo 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.1.Short titleThis Act may be cited as the Taxpayer Due Process Enhancement Act.2.Suspension of period of limitations on filing a claim for credit or refund during collection action proceedings(a)In generalSection 6330(e)(1) of the Internal Revenue Code of 1986 is amended by inserting subsection (a), (b), or (c) of section 6511 (relating to limitations on credit or refund), after section 6502 (relating to collection after assessment),.(b)Period of limitations on filing a claim for credit or refundSection 6330(e) of such Code is amended by adding at the end the following new paragraph:(3)Period of limitations on filing a claim for credit or refundIn the case of the running of any period of limitations under subsection (a), (b), or (c) of section 6511 with respect to the filing of any claim for credit or refund, paragraph (1)—(A)shall apply only to the extent that such credit or refund relates to an underlying tax liability properly disputed at the hearing requested under this section, and(B)shall not result in a suspension of the running of such period of limitations after any date on which a lapse of a deadline, a court filing, or a court order establishes that the taxpayer has forfeited or otherwise lost the right to pursue such dispute..(c)Cross referenceSection 6511(i) of such Code is amended by adding at the end the following new paragraph:(8)For limitations in case of collection action proceedings, see section 6330(e)..(d)Effective dateThe amendments made by this section shall apply to the running of any period of limitations if such period (determined without regard to the amendments made by this section) ends on or after the date of the enactment of this Act.3.Prohibition on crediting of overpayments against disputed tax liability during collection action proceedings(a)In generalSection 6402 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection:(o)Prohibition on crediting of overpayments against disputed tax liability during collection action proceedingsIf a hearing is properly requested under section 6320(a)(3)(B) or 6330(a)(3)(B), and an underlying tax liability referred to in section 6330(c)(2)(B) is properly disputed at such hearing, such tax liability shall not, except with the consent of the taxpayer, be taken into account under subsection (a) for the period during which the period of limitations for filing a claim for credit or refund relating to such tax liability is suspended by reason of section 6330(e)..(b)Clarification of application of certain levy hearing rules to lien hearingsSection 6330(c)(2)(A) of such Code is amended by striking unpaid tax or the proposed levy and inserting unpaid tax, collection action, or proposed collection action.(c)Effective dates(1)In generalThe amendment made by subsection (a) shall apply with respect to any period described in section 6402(o) of the Internal Revenue Code of 1986 (as added by this section) if any portion of such period is after the date of the enactment of this Act.(2)Clarification of application of certain levy hearing rules to lien hearingsThe amendment made by subsection (b) shall take effect on the date of the enactment of this Act.4.Expansion of jurisdiction of Tax Court(a)In generalSection 6330(d)(1) of the Internal Revenue Code of 1986 is amended to read as follows:(1)Petition for review by Tax Court(A)In generalIn the case of a determination under this section, the person may, within 30 days of such determination, petition the Tax Court for review of—(i)such determination, and(ii)any underlying tax liability referred to in subsection (c)(2)(B) which is properly disputed at the hearing in which such determination is made.(B)Jurisdiction of Tax CourtUpon the filing of a petition, the Tax Court shall have jurisdiction with respect to—(i)the determination referred to in subparagraph (A)(i),(ii)any underlying tax liability referred to in subparagraph (A)(ii), and(iii)any equitable tolling of the 30-day deadline referred to in subparagraph (A).(C)Retention of jurisdictionUpon a determination being made under this section, subparagraphs (A) and (B) shall apply whether or not the Secretary abandons the collection action or proposed collection action at issue in such determination..(b)Effective dateThe amendment made by this section shall apply with respect to petitions filed after the date of the enactment of this Act.January 7, 2026Reported with an amendment, committed to the Committee of the Whole House on the State of the Union, and ordered to be printed
The bill's own words, from our database (synced from the GPO BILLS XML); paragraph breaks added at the bill's section boundaries, nothing else changed.
| Date | Chamber | All Actions |
|---|---|---|
| 12/09/2025 | Library of Congress | Introduced in House |
| 12/09/2025 | Library of Congress | Introduced in House |
| 12/09/2025 | House floor actions | Referred to the House Committee on Ways and Means. |
| 12/10/2025 | House committee actions | Committee Consideration and Mark-up Session Held |
| 12/10/2025 | House committee actions | Ordered to be Reported in the Nature of a Substitute (Amended) by the Yeas and Nays: 41 - 0. |
| 01/07/2026 | Library of Congress | Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428. |
| 01/07/2026 | House floor actions | Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428. |
| 01/07/2026 | House floor actions | Placed on the Union Calendar, Calendar No. 373. |
| 05/19/2026 | House floor actions | Mr. Smith (MO) moved to suspend the rules and pass the bill, as amended. |
| 05/19/2026 | House floor actions | Considered under suspension of the rules. (consideration: CR H3564-3567) |
| 05/19/2026 | House floor actions | DEBATE - The House proceeded with forty minutes of debate on H.R. 6506. |
| 05/19/2026 | Library of Congress | 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) |
| 05/19/2026 | House floor actions | On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564) |
| 05/19/2026 | House floor actions | Motion to reconsider laid on the table Agreed to without objection. |
| 05/20/2026 | Senate | Received in the Senate and Read twice and referred to the Committee on Finance. |
| Title Type | Title |
|---|---|
| Display Title | Taxpayer Due Process Enhancement Act |
| Short Titles from RFS (Referred to Senate) bill text | Taxpayer Due Process Enhancement Act |
| Short Title(s) as Passed House | Taxpayer Due Process Enhancement Act |
| Official Titles from EH (Engrossed in House) bill text | 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. |
| Short Title(s) as Reported to House | Taxpayer Due Process Enhancement Act |
| Short Title(s) as Introduced | Taxpayer Due Process Enhancement Act |
| Official Title as Introduced | 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. |
There are no amendments to this bill.
* = Original cosponsor
| Committee | Activity |
|---|---|
| Senate - Finance Committee | 05/20/2026 Referred To |
| House - Ways and Means Committee | 01/07/2026 Reported By |
| House - Ways and Means Committee | 12/10/2025 Markup By |
| House - Ways and Means Committee | 12/09/2025 Referred To |
No related bill information was received for H.R. 6506.
Policy Area: Taxation
All data on this page comes from our own database (legislation.congress_* tables), synced daily from the GPO govinfo BILLSTATUS and BILLS collections. Formatted after congress.gov; nothing is generated. Member placement is their DW-NOMINATE score (voteview.com, Lewis et al.) - a measurement of roll-call voting behavior, not our judgement. Buckets: Left below −0.50 · Lean Left to −0.25 · Center to +0.25 · Lean Right to +0.50 · Right above +0.50. The bill's Support meter aggregates the people who signed the bill - sponsor and current cosponsors, each counted once - nothing else.