PlainBillCongress, translated.Legislation. Context. Public interest.Received in the Senate and Read twice and referred to the Committee on Finance.
Congressional Research Service
Version 07 · Reported to House · Jan 7, 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.
Showing the opening paragraphs of the official summary.
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.
People & committees
Rep. Moran, Nathaniel [R-TX-1] · R–TX
Legislative record
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Received in the Senate and Read twice and referred to the Committee on Finance.
Motion to reconsider laid on the table Agreed to without objection.
On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564)
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)
DEBATE - The House proceeded with forty minutes of debate on H.R. 6506.
Considered under suspension of the rules. (consideration: CR H3564-3567)
Mr. Smith (MO) moved to suspend the rules and pass the bill, as amended.
Placed on the Union Calendar, Calendar No. 373.
Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.
Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-428.
Ordered to be Reported in the Nature of a Substitute (Amended) by the Yeas and Nays: 41 - 0.
Committee Consideration and Mark-up Session Held
Referred to the House Committee on Ways and Means.
Introduced in House
Introduced in House
Primary sources
Text links open the official source. We currently store references to these documents.
No related bills are listed in this snapshot. This does not establish whether the proposal has appeared in earlier Congresses.
Source last updated: Sep 19, 2026. Consult Congress.gov for the current record.
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Analyze H.R.6506 as objectively as possible. Explain its main provisions, who would be affected, possible benefits and harms, implementation, exceptions, and uncertainties. Present the strongest arguments for and against it, and identify evidence needed to assess its public impact.
Examine H.R.6506 through a progressive lens, focusing on fairness, access, economic inequality, and effects on vulnerable communities. Explain potential benefits, costs, and unintended consequences. Consider the strongest counterarguments and distinguish stated goals from demonstrated outcomes.
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