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Enhanced Taxpayer Rights and Protections for Small Businesses Against the IRS.

This Act significantly strengthens the rights of taxpayers, particularly small businesses, in disputes with the IRS. It introduces stricter penalties for IRS employee misconduct and unauthorized data disclosure, increases civil damages available to citizens, and makes it easier for small businesses to recover legal costs. Crucially, it removes the requirement for partial upfront payment when submitting an Offer-in-Compromise to settle tax debt.
Key points
Maximum civil damages for intentional IRS misconduct increase from $1 million to $5 million; the time limit to file a lawsuit is extended from 2 to 5 years.
Small businesses (under $50M revenue) can recover litigation costs against the IRS without meeting net worth limitations.
The IRS Office of Appeals is prohibited from raising new issues or justifications that were not included in the initial audit determination.
Limits the IRS's ability to place a lien on a taxpayer's principal residence if it would cause economic hardship.
Repeals the requirement for taxpayers to make a partial payment when submitting an Offer-in-Compromise to settle tax debt.
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Additional Information
Print number: 118_S_1177
Sponsor: Sen. Cornyn, John [R-TX]
Process start date: 2023-04-18