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Small Business Taxpayer Bill of Rights Act of 2025

USA119th CongressHR-2782| House 
| Updated: 4/9/2025
David Kustoff

David Kustoff

Republican Representative

Tennessee

Ways and Means Committee, Oversight and Government Reform Committee

  • Introduced
  • In Committee
  • On Floor
  • Passed Chamber
  • Enacted
The Small Business Taxpayer Bill of Rights Act of 2025 aims to significantly enhance protections and rights for small businesses and other taxpayers in their dealings with the Internal Revenue Service (IRS). It introduces measures to increase accountability for IRS employees, strengthen taxpayer appeal rights, and provide greater flexibility in resolving tax disputes. The bill also seeks to prevent discriminatory practices and alleviate financial burdens on taxpayers. The legislation substantially increases the civil damages taxpayers can claim for reckless or intentional disregard of internal revenue laws by IRS employees, raising the maximum from $1 million to $5 million, and for negligence from $100,000 to $500,000. It also quadruples the damages for unauthorized inspection or disclosure of tax returns from $1,000 to $10,000, and extends the statute of limitations for these actions from two to five years. Furthermore, the bill increases monetary penalties for IRS officers and employees who commit offenses related to revenue laws or unauthorized information disclosures, with all these amounts subject to inflation adjustments. A core focus is strengthening the independence of the IRS Appeals process . The bill prohibits ex parte communications between IRS Appeals officers and other IRS employees regarding pending matters, with potential termination for misconduct. Taxpayers are granted the right to an independent conference with the IRS Independent Office of Appeals, excluding Chief Counsel or compliance personnel unless consented to. Additionally, the bill bans the IRS Appeals office from raising new issues, deficiencies, or theories not included in the initial determination. The Act expands access to alternative dispute resolution , allowing taxpayers to request mediation or arbitration and to elect an independent mediator, with cost-sharing provisions that exempt low-income individuals and small businesses. It limits the IRS's ability to enforce liens against a taxpayer's principal residence unless other property is insufficient and it won't cause economic hardship, requiring high-level approval. For business taxpayers, the IRS must consider the economic viability of the business and potential harm to individuals when determining whether to release a levy due to economic hardship. The bill also repeals the partial payment requirement for offers-in-compromise and allows individuals to deduct up to $5,000 in expenses for certain audits if no additional tax liability is found. Finally, the Treasury Inspector General for Tax Administration (TIGTA) is mandated to review IRS criteria for selecting tax returns and tax-exempt status applications to identify and eliminate discrimination, with semiannual reporting requirements.
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Timeline

Bill from Previous Congress

HR 117-7033
Small Business Taxpayer Bill of Rights Act of 2022

Bill from Previous Congress

HR 118-2681
Small Business Taxpayer Bill of Rights Act of 2023
Apr 9, 2025

Latest Companion Bill Action

S 119-1386
Introduced in Senate
Apr 9, 2025
Introduced in House
Apr 9, 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.
  • Bill from Previous Congress

    HR 117-7033
    Small Business Taxpayer Bill of Rights Act of 2022


  • Bill from Previous Congress

    HR 118-2681
    Small Business Taxpayer Bill of Rights Act of 2023


  • April 9, 2025

    Latest Companion Bill Action

    S 119-1386
    Introduced in Senate


  • April 9, 2025
    Introduced in House


  • April 9, 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.

Taxation

Related Bills

  • S 119-1386: Small Business Taxpayer Bill of Rights Act of 2025

Small Business Taxpayer Bill of Rights Act of 2025

USA119th CongressHR-2782| House 
| Updated: 4/9/2025
The Small Business Taxpayer Bill of Rights Act of 2025 aims to significantly enhance protections and rights for small businesses and other taxpayers in their dealings with the Internal Revenue Service (IRS). It introduces measures to increase accountability for IRS employees, strengthen taxpayer appeal rights, and provide greater flexibility in resolving tax disputes. The bill also seeks to prevent discriminatory practices and alleviate financial burdens on taxpayers. The legislation substantially increases the civil damages taxpayers can claim for reckless or intentional disregard of internal revenue laws by IRS employees, raising the maximum from $1 million to $5 million, and for negligence from $100,000 to $500,000. It also quadruples the damages for unauthorized inspection or disclosure of tax returns from $1,000 to $10,000, and extends the statute of limitations for these actions from two to five years. Furthermore, the bill increases monetary penalties for IRS officers and employees who commit offenses related to revenue laws or unauthorized information disclosures, with all these amounts subject to inflation adjustments. A core focus is strengthening the independence of the IRS Appeals process . The bill prohibits ex parte communications between IRS Appeals officers and other IRS employees regarding pending matters, with potential termination for misconduct. Taxpayers are granted the right to an independent conference with the IRS Independent Office of Appeals, excluding Chief Counsel or compliance personnel unless consented to. Additionally, the bill bans the IRS Appeals office from raising new issues, deficiencies, or theories not included in the initial determination. The Act expands access to alternative dispute resolution , allowing taxpayers to request mediation or arbitration and to elect an independent mediator, with cost-sharing provisions that exempt low-income individuals and small businesses. It limits the IRS's ability to enforce liens against a taxpayer's principal residence unless other property is insufficient and it won't cause economic hardship, requiring high-level approval. For business taxpayers, the IRS must consider the economic viability of the business and potential harm to individuals when determining whether to release a levy due to economic hardship. The bill also repeals the partial payment requirement for offers-in-compromise and allows individuals to deduct up to $5,000 in expenses for certain audits if no additional tax liability is found. Finally, the Treasury Inspector General for Tax Administration (TIGTA) is mandated to review IRS criteria for selecting tax returns and tax-exempt status applications to identify and eliminate discrimination, with semiannual reporting requirements.
View Full Text

Suggested Questions

Get AI-generated questions to help you understand this bill better

Timeline

Bill from Previous Congress

HR 117-7033
Small Business Taxpayer Bill of Rights Act of 2022

Bill from Previous Congress

HR 118-2681
Small Business Taxpayer Bill of Rights Act of 2023
Apr 9, 2025

Latest Companion Bill Action

S 119-1386
Introduced in Senate
Apr 9, 2025
Introduced in House
Apr 9, 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.
  • Bill from Previous Congress

    HR 117-7033
    Small Business Taxpayer Bill of Rights Act of 2022


  • Bill from Previous Congress

    HR 118-2681
    Small Business Taxpayer Bill of Rights Act of 2023


  • April 9, 2025

    Latest Companion Bill Action

    S 119-1386
    Introduced in Senate


  • April 9, 2025
    Introduced in House


  • April 9, 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.
David Kustoff

David Kustoff

Republican Representative

Tennessee

Ways and Means Committee, Oversight and Government Reform Committee

Taxation

Related Bills

  • S 119-1386: Small Business Taxpayer Bill of Rights Act of 2025
  • Introduced
  • In Committee
  • On Floor
  • Passed Chamber
  • Enacted