H.R. 6506

119th Congress

In Committee

Taxpayer Due Process Enhancement Act

Sponsored byRepublican:Rep. Moran, Nathaniel [R-TX-1]TX· Introduced 9 December 2025
Open on Congress.gov

1

Cosponsors

15

Actions

0

Amendments

2

Committees

—

Since introduced

Introduced
Committee
Passed Chamber
Passed Both
Enacted
Step 1 of 0
Latest action

Received in the Senate and Read twice and referred to the Committee on Finance.

20 May 2026·2 months ago

Summary

Reported to House · Updated 24 April 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.

Timeline

15 actions

  1. Received in the Senate and Read twice and referred to the Committee on Finance.

    20 May 2026 · IntroReferral

  2. Mr. Smith (MO) moved to suspend the rules and pass the bill, as amended.

    19 May 2026 · Floor

  3. On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564)

    19 May 2026 · Floor

  4. 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)

    19 May 2026 · Floor

  5. Motion to reconsider laid on the table Agreed to without objection.

    19 May 2026 · Floor

  6. DEBATE - The House proceeded with forty minutes of debate on H.R. 6506.

    19 May 2026 · Floor

  7. Considered under suspension of the rules. (consideration: CR H3564-3567)

    19 May 2026 · Floor

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

    7 January 2026 · Committee

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

    7 January 2026 · Calendars

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

    7 January 2026 · Committee

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

    7 January 2026 · Committee

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

    7 January 2026 · Committee

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

    7 January 2026 · Calendars

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

    10 December 2025 · Committee

  15. Committee Consideration and Mark-up Session Held

    10 December 2025 · Committee

  16. Committee Consideration and Mark-up Session Held

    10 December 2025 · Committee

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

    10 December 2025 · Committee

  18. Referred to the House Committee on Ways and Means.

    9 December 2025 · IntroReferral

  19. Referred to the House Committee on Ways and Means.

    9 December 2025 · IntroReferral

  20. Introduced in House

    9 December 2025 · IntroReferral

Sponsorship

1 cosponsors

Sponsor

Republican:Rep. Moran, Nathaniel [R-TX-1]TX

Cosponsors

  • Democrat1100%

Classification

Policy area

Taxation

Legislative subjects

Income tax creditsJurisdiction and venueSpecialized courtsTax administration and collection, taxpayers

Committees

2

  • Ways and Means Committee

    House · Standing

    • Referred To9 Dec 2025
    • Markup By10 Dec 2025
    • Reported By7 Jan 2026

  • Finance Committee

    Senate · Standing

    • Referred To20 May 2026

Reports

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