Small Business Taxpayer Rights: Enhanced Protection and Fairness
This act strengthens the rights of small businesses and individual taxpayers in their interactions with the IRS. It introduces changes that make it easier to claim damages, increase penalties for improper official conduct, and ensure greater independence in appeal processes, aiming to improve fairness and transparency.
Key points
Small businesses can recover litigation costs regardless of net worth if they prevail in tax disputes.
Increased financial penalties for IRS employees for reckless or intentional disregard of tax laws and unauthorized disclosure of information.
Taxpayers gain the right to an independent conference with the IRS Office of Appeals, without the presence of IRS Chief Counsel or compliance personnel, unless consented to.
Introduces mediation or arbitration options for tax disputes, with the choice of an independent mediator.
The IRS cannot raise new issues during internal appeals if they were not part of the initial determination.
Limits the IRS's ability to enforce liens against a taxpayer's primary residence, requiring written determination and assessment of economic hardship.
Facilitates the release of IRS levies due to economic hardship for businesses, considering the viability of the business.
Repeals the partial payment requirement when submitting offers-in-compromise to the IRS.
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