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People & committees
Rep. Doggett, Lloyd [D-TX-37] · D–TX
Legislative record
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Referred to the House Committee on Ways and Means.
Introduced in House
Introduced in House
Primary sources
Text links open the official source. We also preserved the text version used in the PlainBill explanation below.
No related bills are listed in this snapshot. This does not establish whether the proposal has appeared in earlier Congresses.
Source last updated: Sep 22, 2026. Consult Congress.gov for the current record.
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PlainBill explanation
Based on the full Introduced in House · 2026-09-03 text. This explanation has not received human editorial review. This overview describes the proposal’s major provisions; it does not establish what its real-world effects would be.
This proposal would set procedural protections for tax-exempt organizations facing examinations or decisions that could remove or change their tax-exempt status. It would require detailed notices, documented reasons, time to answer information requests, and opportunities for conferences and appeals. Churches would retain a separate examination framework with added protections. The bill says its changes would apply to examinations begun after December 31, 2024.
In the case of an organization exempt from tax under section 501(a) (other than a church) the Secretary may begin a tax exempt examination only if the notice requirements of subsection (b) are met.
The Secretary may make an adverse determination with respect to an organization’s status as exempt from tax under section 501(a) only if— (A) an examination begun pursuant to paragraph (1), or in the case of a church, section 7611(b), sufficiently supports such determination, and (B) the due process requirements of subsection (c) are met.
The due process requirements of this subsection shall be treated as met with respect to an examination if the Secretary— (A) generates and maintains a record of the examination that meets the requirements of paragraph (2) and that constitutes prima facie evidence for the conclusion reached, (B) makes requests for information and documentation only as provided in paragraph (3), (C) affords the organization the opportunity for conferences as provided in paragraphs (4) and (5), and (D) notifies the organization of any adverse decision made, and any rights to protest or appeal such decision, as provided in paragraph (6).
The deadline for response by an organization to any such request shall not be less than 30 days from the date of such request.
The amendments made by this section shall apply to examinations begun after December 31, 2024.
Section 1 would name the bill the Protecting the Rights of Organizations Fairly Act of 2026, or PROOF Act.
This Act may be cited as the Protecting the Rights of Organizations Fairly Act of 2026 or the PROOF Act.
Section 2 would require the specified notice before an examination of a non-church organization exempt under section 501(a). An adverse decision about an organization's exempt status, including a church's, would require sufficient support from an examination begun under the applicable rules and compliance with the proposed procedural protections.
(1) Examination In the case of an organization exempt from tax under section 501(a) (other than a church) the Secretary may begin a tax exempt examination only if the notice requirements of subsection (b) are met. (2) Revocation of status The Secretary may make an adverse determination with respect to an organization’s status as exempt from tax under section 501(a) only if— (A) an examination begun pursuant to paragraph (1), or in the case of a church, section 7611(b), sufficiently supports such determination, and (B) the due process requirements of subsection (c) are met.
The examination notice would have to explain clearly what is being examined, the relevant tax-law provisions and Treasury regulations, and the tax periods involved. It would also have to identify the examiner and supervisor and provide their contact information.
the Secretary provides written notice to the organization of the examination that includes in clear and sufficient detail the following: (A) A statement that the organization has been selected for examination of whether the organization is exempt from tax under section 501(a). (B) A statement that identifies the general subject matter and issue areas that are the basis for the examination and the provisions of this title, and any related Treasury Regulations, which authorize such examination or which may be otherwise involved in such examination. (C) Identification of the tax periods subject to examination. (D) The name and contact information of the individual assigned to the examination and the individual’s supervisor.
The notice would have to explain the organization's rights, including representation by a lawyer or authorized representative and a supervisory conference. It would also have to offer to consider a response or hold an opening conference to address concerns about the examination.
(E) An explanation of the organization’s rights during the examination, including the right to representation by legal counsel or an authorized representative and the right to request a supervisory conference pursuant to subsection (c)(4). (F) An offer to consider a response or have an opening conference between the organization and the Secretary to seek to resolve concerns relating to such examination.
Examining an issue outside the original notice would require another written notice meeting the same notice requirements for that issue.
In the case of any issue not identified in the notice prescribed by paragraph (1), the notice requirements of this subsection shall not be treated as met with respect to any examination of such issue unless the Secretary provides a subsequent written notice to the organization that meets the requirements of paragraph (1) with respect to the issue.
The Secretary would have to maintain an examination record that provides evidence sufficient on its face to support the conclusion. The record would document the examination's basis, information requests, the organization's responses, the examiner's factual and legal analysis, and any proposed determination, along with a dated chronology of significant events.
generates and maintains a record of the examination that meets the requirements of paragraph (2) and that constitutes prima facie evidence for the conclusion reached
such record includes— (i) documentation of— (I) the basis for the examination, (II) each information or document request made to the organization, (III) the organization’s responses to any notices, inquiries, requests, or other communications, (IV) the examiner’s analysis of the applicable facts and law, and (V) the basis for any proposed determination, and (ii) a date-specific case chronology reflecting all significant contacts, decisions, and actions taken during the examination
Once the examination record is complete or the organization submits a protest or appeal of the proposed adverse determination, whichever happens first, the organization could request the record in writing. Disclosure would be required within 30 days. Legally privileged communications would be excluded, but required record information found only in those communications would have to be summarized in sufficient detail.
After completion of the record of the examination, or after submission of a protest or appeal by the organization of the proposed adverse determination under paragraph (6), whichever is earlier, on written request from the organization, the Secretary shall not later than 30 days after such request disclose to the organization the contents of the record described in subparagraph (A).
Clause (i) shall not apply to any privileged communications, except that if any contents of the record described in subparagraph (A) are otherwise contained solely within a privileged communication, the disclosure under clause (i) shall include a summary of such contents in sufficient detail to apprise the organization of such contents as so described.
Information requests would have to describe the material sought clearly enough for the organization to identify and produce it, explain its connection to the examination, and allow at least 30 days to respond. Failure to answer a request that fails these requirements could not serve as a basis for an adverse tax-exempt-status determination.
All requests by the Secretary seeking information or documentation from the organization shall include the following: (i) A description of the documents or other information sought sufficient in detail to allow the organization to identify and produce responsive materials. (ii) An explanation of the connection between the request and the subject matter of the examination.
(B) Period for response The deadline for response by an organization to any such request shall not be less than 30 days from the date of such request. (C) Deficient requests Failure by the organization to respond to an examination request that does not meet the requirements of this paragraph shall not be treated as a basis for an adverse determination with respect to an organization’s status as an organization exempt from tax under section 501(a).
An organization could request a conference with the examiner's supervisor about a disputed issue during the examination. The Secretary would have to acknowledge the request within 10 business days, hold the conference within 30 days unless a longer period is agreed upon, and provide a written summary within 15 business days after the conference.
In the case of a request by the organization during the examination for a conference with the examining agent’s supervisor regarding any issue in dispute between the organization and the examining agent, the Secretary shall— (A) not later than 10 business days after such request is made, acknowledge such request, (B) not later than 30 days after such request is made, or such longer period as may be agreed upon, hold such requested conference, at which the organization may present its position on any issue in dispute, (C) not later than 15 business days after such conference, provide a written summary of the conference that includes a description of any decisions made with respect to an issue in dispute.
Before issuing a proposed adverse determination letter, the Secretary would have to make a closing conference available. It would explain the findings, supporting facts and legal authority, and appeal rights and deadlines. A written conference summary would be due within 15 business days afterward.
prior to issuing a proposed adverse determination letter with respect to such decision, the Secretary shall— (A) make available a conference, at which there shall be provided with respect to the adverse decision— (i) a summary of the examination findings, (ii) the legal and factual basis for the adverse decision, including the specific legal authority and conclusions from the record of the examination that support the decision, and (iii) an explanation of the organization’s appeal rights and applicable deadlines, and (B) provide a written summary of such conference not later than 15 business days thereafter.
A final adverse determination letter could not be issued until at least 30 days after a proposed letter was provided. The proposed letter would have to state prominently how the organization's exemption would be revoked, modified, or otherwise adversely affected, explain the factual and legal basis, and give the proposed effective date.
The Secretary shall not issue a final adverse determination letter in the case of an adverse decision with respect to the organization’s tax exempt status under section 501(a), unless, and in no case earlier than 30 days after, the Secretary provides a proposed adverse determination letter to the organization.
(i) A prominent statement of how the Secretary is proposing to revoke, modify, or adversely affect the organization’s tax-exempt status under section 501(a). (ii) A summary of the examination findings and the legal and factual basis for the determination, including the specific legal authority and conclusions from the record of the examination that support the determination. (iii) A statement of the proposed effective date of the determination.
The proposed letter would also have to explain how to protest, seek an administrative appeal and a conference with the Internal Revenue Service Independent Office of Appeals, or start a court proceeding under section 7428. It would have to explain deadlines, the consequences of using or not using these rights, and when a final letter could issue without a protest or appeal.
(iv) An explanation of the organization’s protest and appeal rights, including submitting to the Secretary a protest of the proposed adverse determination letter, administrative appeal and requesting a conference with the Internal Revenue Service Independent Office of Appeals for consideration of the proposed adverse determination, and initiating a judicial proceeding under section 7428. (v) An explanation of the applicable deadlines for such protests and appeals, and the legal consequences of exercising (or failing to exercise) such rights. (vi) A statement of the date on which the Secretary may issue a final adverse determination letter in the absence of a protest or appeal.
Church examination notices would have to explain representation rights and the right to request a supervisory conference. Expanding a church examination would also require supplementary written notice describing the additional church records and activities to be examined.
Section 7611(b)(3)(A) of such Code is amended by redesignating clauses (iii) and (iv) as clauses (iv) and (v), respectively, and by inserting after clause (ii) the following new clause: (iii) an explanation of the church’s rights during the examination, including the right to representation by legal counsel or an authorized representative and the right to request a supervisory conference pursuant to section 7611A(c)(4)
Section 7611(b)(4) of such Code is amended by inserting before the period at the end the following: and the Secretary provides the church a supplementary written notice that includes a description of any such church records and activities which the Secretary seeks to examine.
The church-notice amendments also propose adding an offer to consider a response before the existing offer of a conference. That instruction cites section 7211(b)(3)(A)(iv), although the preceding amendment redesignates clauses in section 7611(b)(3)(A); the supplied text leaves this discrepancy unresolved.
Section 7611(b)(3)(A) of such Code is amended by redesignating clauses (iii) and (iv) as clauses (iv) and (v), respectively
(2) Consideration of response to notice of examination Section 7211(b)(3)(A)(iv) of such Code, as redesignated by paragraph (1), is amended by inserting an offer to consider a response and before an offer to have a conference.
An organization requesting review within 30 days after the proposed adverse determination letter would have access to the referenced appeals resolution process and a conference if requested. The Internal Revenue Service Independent Office of Appeals would have to acknowledge a timely request within 10 business days and schedule and hold a requested conference within 90 days of receiving the request.
In the case of a proposed adverse determination letter with respect to an organization’s tax exempt status under section 501(a), the resolution process described in paragraph (3) shall be available to the organization, and a conference shall be provided, with respect to such proposed adverse determination if requested by the organization not later than 30 days after the date of the proposed adverse determination letter.
In the case of such a timely request by the organization, the Internal Revenue Service Independent Office of Appeals shall— (i) not later than 10 business days after receipt of such request, acknowledge such request, and (ii) in the case of a request for a conference, not later than 90 days after receipt of such request, schedule and hold such conference.
The amendments would apply to examinations begun after December 31, 2024.
(e) Effective date The amendments made by this section shall apply to examinations begun after December 31, 2024.
The supplied action snapshot, updated September 22, 2026, records introduction in the House and referral to the House Committee on Ways and Means on September 3, 2026.
Source snapshot updated 2026-09-22T15:28:22Z. 2026-09-03: Referred to the House Committee on Ways and Means. 2026-09-03: Introduced in House
A closer look
Reviewed version: Introduced in House · 2026-09-03. These findings describe provisions and who may benefit; they are not judgments of waste, corruption, or motive.
This review covers the supplied bill text. “None identified” does not rule out provisions in later versions or accompanying reports and disclosures.
Provisions outside the bill’s main subject, or policy changes attached to appropriations.
None identified in the reviewed text
No unrelated provision or policy change attached to appropriations was identified in the complete supplied introduced text. This conclusion applies only to that version, not other versions or accompanying materials.
Spending directed to particular recipients or places outside ordinary competitive or formula-based allocation.
None identified in the reviewed text
No congressionally directed spending for particular recipients or places was identified in the complete supplied introduced text. This conclusion is limited to that version and does not establish the contents of other versions or accompanying materials.
Narrow exceptions, exemptions, or preferential treatment that warrant a closer look.
None identified in the reviewed text
No materially narrow preferential benefit was identified in the complete supplied introduced text under the requested definition. Procedural protections for the covered organizations and coordination of generally available rights do not alone establish preferential treatment. This conclusion is limited to that version.
Full text preserved for this analysis. Legislative record snapshot: Sep 22, 2026. How PlainBill uses AI