HR 2782 — Small Business Taxpayer Bill of Rights Act of 2025

Bill Text

• Introduced Introduced in House Current html April 09, 2025

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The bill enhances taxpayer rights for small businesses by modifying various provisions in the Internal Revenue Code to provide more protections and increased penalties for misconduct by IRS officers.

• 7430(c)(4)

  the period at the end of clause (ii) → , and

  Adds a new clause allowing small businesses to be eligible for costs and fees regardless of net worth.

• 7430(c)(4)

  (F) Eligible small business.-- For purposes of subparagraph (D)(iii), the term `eligible small business' means, with respect to any proceeding commenced in a taxable year-- (I) a corporation the stock of which is not publicly traded, (II) a partnership, or (III) a sole proprietorship, if the average annual gross receipts of such corporation, partnership, or sole proprietorship for the 3-taxable-year period preceding such taxable year does not exceed $50,000,000.

  Defines 'eligible small business' for the purposes of awarding costs and fees.

• 7433(b)

  $1,000,000 ($100,000, in the case of negligence) → $5,000,000 ($500,000, in the case of negligence)

  Increases the maximum civil damages allowed for reckless or intentional disregard of internal revenue laws.

• 7433(d)(3)

  2 years → 5 years

  Extends the time allowed to bring action for damages against IRS employees from 2 years to 5 years.

• 7214(a)

  $10,000 → $25,000

  Increases the penalty for certain offenses by IRS officers from $10,000 to $25,000.

• 7214(b)

  $5,000 → $10,000

  Increases the penalty for other offenses by IRS officers from $5,000 to $10,000.

• 7431(c)(1)(A)

  $1,000 → $10,000

  Increases the damages for unauthorized inspection or disclosure of tax returns from $1,000 to $10,000.

• 7431(d)

  2 years → 5 years

  Extends the period for bringing actions for unauthorized inspection or disclosure from 2 years to 5 years.

• 1001

  (c) Right to Independent Conference.--Under the organization plan of the Internal Revenue Service, a taxpayer shall have the right to a conference with the Internal Revenue Service Independent Office of Appeals...

  Establishes a right for taxpayers to have an independent conference without IRS compliance personnel.

• 7123

  (d) Availability of Dispute Resolutions.--The procedures prescribed under subsection (b)(1) and the pilot program established under subsection (b)(2)...

  Allows taxpayers to request mediation or arbitration for disputes, expanding access to alternative dispute resolution.

Action History

1. April 09, 2025

   Introduced in House

2. April 09, 2025

   Introduced in House

3. April 09, 2025

   Referred to the Committee on Ways and Means, and in addition to the Committee on Oversight and Government Reform, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.

4. April 09, 2025

   Referred to the Committee on Ways and Means, and in addition to the Committee on Oversight and Government Reform, for a period to be subsequently determined by the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned.

Sponsors

• David Kustoff · Primary

Subjects