HR 6506 119th Congress
Taxpayer Due Process Enhancement 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.
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Bill journey
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Introduction Congress.gov
Introduced
Introduced in the House.
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Referred to the House Committee on Ways and Means.
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Introduced in House
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Introduced in House
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Introduced in House
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Ordered to be Reported in the Nature of a Substitute (Amended) by the Yeas and Nays: 41 - 0.
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Committee Consideration and Mark-up Session Held
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Placed on the Union Calendar, Calendar No. 373.
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Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.
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Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.
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Reported in House
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Engrossed in House
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Mr. Smith (MO) moved to suspend the rules and pass the bill, as amended.
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Considered under suspension of the rules. (consideration: CR H3564-3567)
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DEBATE - The House proceeded with forty minutes of debate on H.R. 6506.
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On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564)
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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)
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Motion to reconsider laid on the table Agreed to without objection.
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Received in the Senate and Read twice and referred to the Committee on Finance.
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Referred in Senate
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View the complete bill journey as an accessible table
| Date and time | Record | Official detail | Source |
|---|---|---|---|
| IntroductionIntroduced | Introduced in the House. | Congress.gov | |
| Official actionReferred to the House Committee on Ways and Means. | No additional detail supplied.IntroReferral · House floor actions · Code H11100 | Congress.gov | |
| Official actionIntroduced in House | No additional detail supplied.IntroReferral · Library of Congress · Code Intro-H | Congress.gov | |
| Official actionIntroduced in House | No additional detail supplied.IntroReferral · Library of Congress · Code 1000 | Congress.gov | |
| Text versionIntroduced in House | A dated text-version record is available. | Congress.gov | |
| Official actionOrdered to be Reported in the Nature of a Substitute (Amended) by the Yeas and Nays: 41 - 0. | No additional detail supplied.Committee · House committee actions · Code H19000 | Congress.gov | |
| Official actionCommittee Consideration and Mark-up Session Held | No additional detail supplied.Committee · House committee actions · Code H15001 | Congress.gov | |
| Official actionPlaced on the Union Calendar, Calendar No. 373. | No additional detail supplied.Calendars · House floor actions · Code H12410 | Congress.gov | |
| Official actionReported (Amended) by the Committee on Ways and Means. H. Rept. 119-428. | No additional detail supplied.Committee · House floor actions · Code H12200 | Congress.gov | |
| Official actionReported (Amended) by the Committee on Ways and Means. H. Rept. 119-428. | No additional detail supplied.Committee · Library of Congress · Code 5000 | Congress.gov | |
| Text versionReported in House | A dated text-version record is available. | Congress.gov | |
| Text versionEngrossed in House | A dated text-version record is available. | Congress.gov | |
| Official actionMr. Smith (MO) moved to suspend the rules and pass the bill, as amended. | No additional detail supplied.Floor · House floor actions · Code H30300 | Congress.gov | |
| Official actionConsidered under suspension of the rules. (consideration: CR H3564-3567) | No additional detail supplied.Floor · House floor actions · Code H30000 | Congress.gov | |
| Official actionDEBATE - The House proceeded with forty minutes of debate on H.R. 6506. | No additional detail supplied.Floor · House floor actions · Code H8D000 | Congress.gov | |
| Official actionOn motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564) | No additional detail supplied.Floor · House floor actions · Code H37300 | Congress.gov | |
| Official actionPassed/agreed to in House: On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564) | No additional detail supplied.Floor · Library of Congress · Code 8000 | Congress.gov | |
| Official actionMotion to reconsider laid on the table Agreed to without objection. | No additional detail supplied.Floor · House floor actions · Code H38310 | Congress.gov | |
| Official actionReceived in the Senate and Read twice and referred to the Committee on Finance. | No additional detail supplied.IntroReferral · Senate | Congress.gov | |
| Text versionReferred in Senate | A dated text-version record is available. | Congress.gov |
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Congressional Research Service
CRS summary
Taxpayer Due Process Enhancement ActThis 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 billsuspends 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), andprovides that the Tax Court retains its jurisdiction if the IRS abandons collection actions.
Official documents
Text versions
- Referred in SenateMay 20, 2026
- Engrossed in HouseMay 19, 2026
- Reported in HouseJan 7, 2026
- Introduced in HouseDec 9, 2025