Both sides have signed this (Bill Ranking)
S. 4964 · 119th Congress (2025-2026)
2 members · Left 1 · Center 0 · Right 1 (Bill Ranking)
| Sponsor | Sen. Marshall, Roger (R-KS) (Introduced 07/14/2026) |
|---|---|
| Sponsor Voting Record | Right · DW-NOMINATE +0.61 · 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 |
| Latest Action | 07/14/2026 Read twice and referred to the Committee on Finance. |
| Roll Call Votes | There have been no roll call votes |
| Source | view on congress.gov → |
Introduced in Senate (07/14/2026)
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.
119 S4964 IS: Protecting Innocent Taxpayers from Endless Assessments Act U.S. Senate 2026-07-14 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. II119th CONGRESS2d SessionS. 4964IN THE SENATE OF THE UNITED STATESJuly 14, 2026Mr. Marshall (for himself and Mr. Welch) introduced the following bill; which was read twice and referred to the Committee on FinanceA BILLTo 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.1.Short titleThis Act may be cited as the Protecting Innocent Taxpayers from Endless Assessments Act.2.Limitation period not extended for victims of preparer fraud(a)In generalSection 6501(c)(1) of the Internal Revenue Code of 1986 is amended by inserting by the taxpayer after intent.(b)Effective dateThe amendment made by this section shall apply to assessments made or proceedings begun after the date of enactment of this Act.
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 |
|---|---|---|
| 07/14/2026 | Library of Congress | Introduced in Senate |
| 07/14/2026 | Senate | Read twice and referred to the Committee on Finance. |
| Title Type | Title |
|---|---|
| Official Title as Introduced | 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. |
| Display Title | Protecting Innocent Taxpayers from Endless Assessments Act |
| Short Title(s) as Introduced | Protecting Innocent Taxpayers from Endless Assessments Act |
There are no amendments to this bill.
* = Original cosponsor
| Committee | Activity |
|---|---|
| Senate - Finance Committee | 07/14/2026 Referred To |
No related bill information was received for S. 4964.
Policy Area: Taxation
No legislative subjects have been assigned yet.
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.