119th Congress · introduced in the House · Dec 9, 2025
Taxpayer Due Process Enhancement Act
Official title from Congress.gov
Latest action (May 20, 2026): Received in the Senate and Read twice and referred to the Committee on Finance.
View on Congress.govPolicy area: Taxation
Congressional Research Service summary, version: Reported to House (Jan 7, 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),
Show the full summary (2 more paragraphs)Includes amendment, cloture, and procedural votes. Each is labeled with its exact question; only a passage question is a vote to pass the bill.
No recorded roll calls on this bill in coverage.
Received in the Senate and Read twice and referred to the Committee on Finance.
Motion to reconsider laid on the table Agreed to without objection.
On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564)
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)
DEBATE - The House proceeded with forty minutes of debate on H.R. 6506.
Considered under suspension of the rules. (consideration: CR H3564-3567)
Mr. Smith (MO) moved to suspend the rules and pass the bill, as amended.
Placed on the Union Calendar, Calendar No. 373.
Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.
Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.
Ordered to be Reported in the Nature of a Substitute (Amended) by the Yeas and Nays: 41 - 0.
Committee Consideration and Mark-up Session Held
Referred to the House Committee on Ways and Means.
Introduced in House
Introduced in House
Actions from Congress.gov, newest first.
Income tax credits · Jurisdiction and venue · Specialized courts · Tax administration and collection, taxpayers
LD-2 reports whose issue descriptions explicitly cite this bill (bill type and number validated against Congress.gov records). A citation does not establish the client's position or any contact with a member.
Loading lobbying reportsCoverage: reports for 2025 onward, posted Jan 1, 2025 through Oct 23, 2026.
2 citations.
NATIONAL TAXPAYERS UNION · lobbying firm or registrant: NATIONAL TAXPAYERS UNION
2025 Q4 report (Oct 1, 2025 – Dec 31, 2025) · posted Jan 21, 2026 · issue area: Taxation/Internal Revenue Code
$30,000
Spent on own lobbying
…ayment Fairness Act HR 997National Taxpayer Advocate Enhancement Act HR 517Filing Relief for Natural Disasters Act HR 6495Taxpayer Notification and Privacy Act HR 6506Taxpayer Due Process Enhancement Act HR 1491 Disaster Related Extension of Deadlines Act Stronger Start for Working Families Act HR 1One Big Beautiful Bill Act…
Congress inferred from the report year; bill number and the title cited with it match Congress.gov records, and the bill predates the report. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing
CHAMBER OF COMMERCE OF THE U.S.A. · lobbying firm or registrant: CHAMBER OF COMMERCE OF THE U.S.A.
2025 Q4 report (Oct 1, 2025 – Dec 31, 2025) · posted Jan 20, 2026 · issue area: Taxation/Internal Revenue Code
$17,960,000
Spent on own lobbying
…/S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.R. 6231/S. 5370, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 6506, Taxpayer Due Process Enhancement Act S. 615, Chemical Tax Repeal Act S. 796, Book Minimum Repeal Tax S. 1443, Mobile Workforce State Income Tax Simplification…
Congress inferred from the report year; bill number and the title cited with it match Congress.gov records, and the bill predates the report. The amount is lobbying spending for every issue on this report, not this bill alone, and none of it is paid to any member of Congress. View filing