```

[Senate Report 114-14]
[From the U.S. Government Publishing Office]

                                                        Calendar No. 37
114th Congress     }                                     {       Report
                                 SENATE
 1st Session       }                                     {       114-14

======================================================================

 
    IMPROVE ACCESS AND ADMINISTRATION OF THE UNITED STATES TAX COURT

                                _______
                                

                 April 14, 2015.--Ordered to be printed

                                _______
                                

               Mr. Hatch, from the Committee on Finance, 
                        submitted the following

                              R E P O R T

                         [To accompany S. 903]

    The Committee on Finance, having considered an original 
bill, S. 903, to amend the Internal Revenue Code of 1986 to 
improve access and administration of the United States Tax 
Court, having considered the same, reports favorably thereon 
without amendment and recommends that the bill do pass.

                                CONTENTS

                                                                   Page
 I. LEGISLATIVE BACKGROUND............................................2
II. EXPLANATION OF THE BILL...........................................2
        A. Access to the United States Tax Court.................     2
            1. Filing period for interest abatement cases (sec. 
                101 of the bill and sec. 6404 of the Code).......     2
            2. Small tax case election for interest abatement 
                cases (sec. 102 of the bill and secs. 6404 and 
                7463 of the Code)................................     3
            3. Venue for appeal of spousal relief and collection 
                cases (sec. 103 of the bill and sec. 7482 of the 
                Code)............................................     4
            4. Suspension of running of period for filing 
                petition of spousal relief and collection cases 
                (sec. 104 of the bill and secs. 6015 and 6330 of 
                the Code)........................................     5
            5. Application of federal rules of evidence (sec. 105 
                of the bill and sec. 7453 of the Code)...........     6
        B. U.S. Tax Court Administration.........................     7
            1. Judicial conduct and disability procedures (sec. 
                201 of the bill and new sec. 7466 of the Code)...     7
            2. Administration, judicial conference, and fees 
                (sec. 202 of the bill; Code sec. 7473; and new 
                secs. 7470 and 7470A of the Code)................     8
        C. Clarification relating to the United States Tax Court 
            (sec. 301 of the bill and sec. 7441 of the Code).....     9
III.BUDGET EFFECTS OF THE BILL.......................................10

IV. VOTES OF THE COMMITTEE...........................................11
 V. REGULATORY IMPACT AND OTHER MATTERS..............................11
VI. CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED............12

                       I. LEGISLATIVE BACKGROUND

    The Committee on Finance, having considered S. 903, a bill 
to amend the Internal Revenue Code of 1986 to improve access 
and administration of the United States Tax Court, reports 
favorably thereon without amendment and recommends that the 
bill do pass.

Background and need for legislative action

    Background.--Based on a proposal recommended by Chairman 
Hatch and Ranking Member Wyden, the Committee on Finance marked 
up original legislation (a bill to amend the Internal Revenue 
Code of 1986 to improve access and administration of the U.S. 
Tax Court) on February 11, 2015, and, with a majority present, 
ordered the bill favorably reported, without amendments, on 
that date. This report describes the provisions of the bill.
    Need for legislative action.--Changes to the provisions 
limiting access to the U.S. Tax Court are needed to assure 
access to a prepayment forum for persons claiming spousal 
relief, challenging the propriety of certain collection actions 
or requesting interest abatement and to conform the treatment 
of bankrupt taxpayers seeking such relief with those seeking 
redetermination of other types of administrative action. In 
addition, the perceived independence of the U.S. Tax Court 
would be enhanced by greater autonomy in its administration of 
fees it collects, as well as clarification that it is not part 
of the Executive Branch.

                      II. EXPLANATION OF THE BILL

                A. Access to the United States Tax Court

1. Filing period for interest abatement cases (sec. 101 of the bill and 
                         sec. 6404 of the Code)

                              PRESENT LAW

    The Internal Revenue Code of 1986, as amended vests with 
the United States Tax Court (herein the ``Tax Court'') 
jurisdiction over actions brought by a taxpayer for review of a 
denial of a request for interest abatement if (1) the taxpayer 
meets certain net worth requirements, and (2) the petition is 
filed within 180 days of mailing of a final determination by 
the Secretary not to abate interest.\1\ In the absence of the 
mailing of a final determination by the Secretary, the Code 
does not authorize the filing of a Tax Court petition and, 
accordingly, does not confer jurisdiction on the Tax Court in 
such circumstances.\2\ Hence, where the Secretary fails to 
respond to a taxpayer's claim for abatement of interest, the 
taxpayer is unable to seek judicial review of the claim.
---------------------------------------------------------------------------
    \1\Sec. 6404(h). Unless otherwise stated, all section references 
are to the Internal Revenue Code of 1986, as amended (the ``Code'').
    \2\Sec. 6404(h).
---------------------------------------------------------------------------

                           REASONS FOR CHANGE

    Claims for abatement of interest generally, in whole or in 
part, raise questions of administrative error, inaction or 
abuse of discretion as a basis for suspending accrual of 
interest on underpayments of tax. The only prepayment forum in 
which such claims can be addressed is the U.S. Tax Court. The 
Committee believes that inaction by the government after a 
reasonable time in which to consider the claim for abatement 
should not deprive taxpayers' access to judicial review of 
claims that may implicate administrative error, inaction or 
abuse of discretion.

                        EXPLANATION OF PROVISION

    The provision amends the Code, relating to review of 
denials of requests for abatement of interest, to provide that 
a petition under the section may be filed with the Tax Court 
upon the expiration of a 180-day period after the filing with 
the IRS of a claim (in such form as the Secretary may 
prescribe) for abatement of interest, in instances where the 
Secretary has failed to issue a final determination within that 
period.

                             EFFECTIVE DATE

    The provision is effective for claims filed after the date 
of enactment.

 2. Small tax case election for interest abatement cases (sec. 102 of 
             the bill and secs. 6404 and 7463 of the Code)

                              PRESENT LAW

    The Code provides certain proceedings for small tax cases, 
generally those that involve disputes of $50,000 or less.\3\ 
Under the Code, the Tax Court has exclusive jurisdiction to 
review a failure by the Secretary to abate interest.\4\ 
However, the Code presently does not authorize cases to be 
conducted using small tax case procedures, unless the issue 
arises as part of a request for review of collection 
actions.\5\
---------------------------------------------------------------------------
    \3\Sec. 7463. These cases are handled under less formal procedures 
than regular cases. The Tax Court's decision in a small tax case is 
final and cannot be appealed to any court by the IRS or by the 
petitioner. See sec. 7463, Title XVII of the United States Tax Court 
rules, and 
http://www.ustaxcourt.gov/forms/Petition_Kit.pdf.
    \4\Sec. 6404(h). Hinck v. United States, 127 S.Ct. 2011 (2007).
    \5\Secs. 7463, 6330.
---------------------------------------------------------------------------

                           REASONS FOR CHANGE

    At present, a petition to the Tax Court to review a 
determination denying interest abatement is permitted, but 
election to apply the small tax case procedures is generally 
not available. Small tax case procedures permit many taxpayers 
with relatively small or uncomplicated issues to seek speedy 
resolution in a less formal proceeding in which they can 
represent themselves, without assistance of counsel. The 
Committee believes that access to simplified court procedures 
is appropriate in small claims for interest abatement, 
regardless of whether the issue is raised as part of a request 
for review of collection actions taken by the IRS.

                        EXPLANATION OF PROVISION

    The provision amends the Code, relating to additional cases 
which may be conducted as a small tax case, by adding a new 
paragraph (3) enumerating petitions brought under section 
6404(h), for review of a decision by the Secretary not to abate 
interest, as a matter which may be conducted under section 
7463. The provision extends the small tax case procedures to 
actions for interest abatement in which the total amount of 
interest for which abatement is sought does not exceed $50,000.

                             EFFECTIVE DATE

    The provision applies to cases pending as of the day after 
the date of enactment, and cases commencing after such date of 
enactment.

3. Venue for appeal of spousal relief and collection cases (sec. 103 of 
                  the bill and sec. 7482 of the Code)

                              PRESENT LAW

    Sections 6015, 6320, and 6330 provide rights for taxpayers, 
principally through the establishment of administrative 
procedures and judicial review of administrative actions taken 
in matters involving spousal relief from joint and several 
liability and collection of taxes by lien and levy. The Tax 
Court is vested with jurisdiction to render decisions on the 
taxpayer's entitlement to relief under these provisions.
    Section 7482 provides for appellate review of Tax Court 
decisions by the U.S. Court of Appeals and subsection (b) of 
that statute governs venue for such review. In general, section 
7482 enumerates types of cases appealable to the U.S. Court of 
Appeals for the circuit in which is located the taxpayer's 
legal residence, principal place of business, or principal 
office or agency and then establishes a default rule for review 
of all other cases by the U.S. Court of Appeals for the 
District of Columbia. Sections 6015, 6320, and 6330 are not 
among those expressly identified as appealable to the circuit 
of residence or principal business/office. However, routine 
practice since enactment, on the part of both the litigants and 
the courts, has been to treat such cases as appealable to the 
U.S. Court of Appeals for the circuit corresponding to the 
petitioner's residence or principal business or office.

                           REASONS FOR CHANGE

    The Committee has learned that the failure to identify 
spousal relief cases and certain collection due process cases 
as cases in which venue for appeal should be determined by 
legal residence, place of business or principal office has led 
to questions about whether the default rule for venue for 
appeal should apply. Under the default rule, venue would lie 
with the U.S. Court of Appeals for the District of Columbia, 
rather than the circuit in which the taxpayer's residence or 
business is located. The Committee believes that application of 
the default rule would unnecessarily complicate access to 
appellate review. Rather than relying on continuation of the 
ability of the litigants to agree on a mutually acceptable 
venue for appeal, the Committee believes it is preferable to 
correct the venue statutes to ensure access to the venue that 
corresponds to residence or principal business or office.

                        EXPLANATION OF PROVISION

    The provision amends section 7482(b) to clarify that Tax 
Court decisions rendered in cases involving petitions under 
sections 6015, 6320, or 6330 follow the generally applicable 
rule for appellate review. That rule provides that the cases 
are appealable to the U.S. Court of Appeals for the circuit in 
which is located the petitioner's legal residence in the case 
of an individual or the petitioner's principal place of 
business or principal office of agency in the case of an entity 
other than an individual.

                             EFFECTIVE DATE

    The provision applies to petitions filed after the date of 
enactment. No inference is intended with respect to the 
application of section 7482 to petitions filed on or before the 
date of enactment.

   4. Suspension of running of period for filing petition of spousal 
 relief and collection cases (sec. 104 of the bill and secs. 6015 and 
                           6330 of the Code)

                              PRESENT LAW

    Section 6015(e) addresses procedures by which taxpayers may 
petition the Tax Court to determine the appropriate relief 
available to the individual in matters involving spousal relief 
from joint and several liability and collection of taxes by 
lien and levy. It also provides for suspension of the running 
of a period of limitations\6\ on the collection of assessments 
that may apply, limits on tax court jurisdictions in certain 
circumstances, and rules for providing adequate notice of 
proceedings to the other spouse.
---------------------------------------------------------------------------
    \6\Sec. 6502.
---------------------------------------------------------------------------
    Section 6330 disallows levies to be made on property or 
rights to property unless the Secretary has notified the 
taxpayer in writing of their right to a hearing before such 
levy is made. Under subsection (d), once a determination is 
made, the taxpayer may appeal the determination to the Tax 
Court within 30 days. Under subsection (e), the levy actions 
which are the subject of the requested hearing and the running 
of any relevant period of limitations\7\ are suspended for the 
period during which such hearing and appeals are pending.
---------------------------------------------------------------------------
    \7\Secs. 6502, 6531, and 6532.
---------------------------------------------------------------------------
    Neither section 6015 or 6330 includes a rule similar to the 
coordination rule found in the general provisions regarding 
filing a petition with the Tax Court for taxpayers in 
bankruptcy.\8\ Under that rule, the period of the automatic 
stay in bankruptcy is disregarded, and the taxpayer may file 
its petition with the Tax Court within 60 days after the stay 
is lifted.
---------------------------------------------------------------------------
    \8\Sec. 6213(f).
---------------------------------------------------------------------------

                           REASONS FOR CHANGE

    To ensure that taxpayers seeking spousal relief or 
collection due process have rights similar to those of other 
litigants in the Tax Court, the Committee believes it is 
appropriate to extend the general rule of section 6213(f) and 
conform the automatic stay of the Bankruptcy Code with the 
limitations period for petitions to the Tax Court for spousal 
relief and collection due process cases.

                        EXPLANATION OF PROVISION

    The provision adds to existing rules a suspension of the 
running of a period of limitations on filing a petition as 
described in section 6015(e) for a taxpayer who is prohibited 
from filing such a petition under U.S.C. Title 11. The 
suspension is for the period during which the taxpayer is 
prohibited from filing such a petition and for 60 days 
thereafter.
    The provision also adds to existing rules a suspension of 
the running of a period of limitations on filing a petition as 
described in section 6330(e) for a taxpayer who is prohibited 
from filing such a petition under U.S.C. Title 11. The 
suspension is for the period during which the taxpayer is 
prohibited from filing such a petition and for 30 days 
thereafter.

                             EFFECTIVE DATE

    The provision applies to petitions filed under section 
6015(e) of the Code after the date of enactment and to 
petitions filed under section 6330 of the Code after the date 
of enactment.

 5. Application of federal rules of evidence (sec. 105 of the bill and 
                         sec. 7453 of the Code)

                              PRESENT LAW

    In general, the Code provides that the proceedings of the 
Tax Court shall be conducted in accordance with rules of 
practice and procedure (other than rules of evidence) as 
prescribed by the Tax Court, and in accordance with the rules 
of evidence applicable in trials without a jury in the United 
States District Court of the District of Columbia.\9\ The Tax 
Court has interpreted the Code to require the Tax Court to 
apply the evidentiary precedent of the D.C. Circuit in all 
cases,\10\ an exception to the Tax Court's regular practice 
under Golsen v. Commissioner\11\ of applying the precedent of 
the circuit court of appeals to which its decision is 
appealable.
---------------------------------------------------------------------------
    \9\Sec. 7453.
    \10\All cases except those cases in which section 7453 does not 
apply, e.g., small tax cases..
    \11\54 T.C. 742 (1970), aff'd, 445 F.2d 985 (10th Cir. 1971).
---------------------------------------------------------------------------
    The Federal Rules of Evidence\12\ are the applicable rules 
of evidence for all Federal district courts in all judicial 
districts, including the District of Columbia. In addition, the 
United States Code includes specific rules and procedures for 
evidence.\13\ Rule 143 of the Rules of Practice and Procedure 
promulgated by the Tax Court, states ``those rules include the 
rules of evidence in the Federal Rules of Civil Procedure and 
any rules of evidence generally applicable in the Federal 
courts (including the United States District Court for the 
District of Columbia).''
---------------------------------------------------------------------------
    \12\The Federal Rules of Evidence, as amended through 2012, under 
the authority of 28 U.S.C. sec. 2074, is available at http://
www.uscourts.gov/uscourts/rules/rules-evidence.pdf. ``The Act to 
Establish Rules of Evidence for Certain Courts and Proceedings,'' Pub. 
L. No. 93-595 (January 2, 1975).
    \13\28 U.S.C. secs. 1731 through 1828.
---------------------------------------------------------------------------

                           REASONS FOR CHANGE

    The Committee believes that present law has led to 
confusion about how the Federal Rules of Evidence are to be 
applied in a Tax Court proceeding, in some instances 
unnecessarily complicating consideration of cases.

                        EXPLANATION OF PROVISION

    The provision amends the Code to provide that proceedings 
of the Tax Court be conducted in accordance with rules of 
practice and procedure as prescribed by the Tax Court, and in 
accordance with Federal Rules of Evidence. Thus, the Tax Court 
will apply the evidentiary precedent of the circuit court of 
appeals to which its decision is appealable.

                             EFFECTIVE DATE

    The provision applies to proceedings commenced after the 
date of enactment, and to the extent that it is just and 
practicable, to all proceedings pending on such date.

                    B. U.S. Tax Court Administration

1. Judicial conduct and disability procedures (sec. 201 of the bill and 
                       new sec. 7466 of the Code)

                              PRESENT LAW

    Under Title 28 of the United States Code, any person is 
authorized to file a complaint alleging that an Article III 
Judge has engaged in conduct prejudicial to the effective and 
expeditious administration of the business of the courts; the 
law also permits any person to allege conduct reflecting a 
covered Judge's inability to perform his or her duties because 
of mental or physical disability.\14\ A judicial council 
exercises specific powers in investigating and taking action 
with respect to such complaints, including paying certain fees 
and allowances incurred in conducting hearings and awarding 
reimbursement of reasonable expenses in appropriate 
circumstances from appropriated funds.\15\ Title 28 directs 
other Article I courts, including the Court of Federal 
Claims\16\ and the Court of Appeals for Veterans Claims,\17\ to 
prescribe similar rules for the filing of complaints with 
respect to the conduct or disability of any Judge and for the 
investigation and resolution of such complaints.
---------------------------------------------------------------------------
    \14\Judicial Conduct and Disability Act of 1980, 28 U.S.C. sections 
351-364. On March 11, 2008, the Judicial Conference of the United 
States promulgated rules governing such proceedings.
    \15\28 U.S.C. chapter 16.
    \16\28 U.S.C. sec. 363.
    \17\38 U.S.C. sec. 7253(g).
---------------------------------------------------------------------------
    Unlike the prescriptions of Title 28 for Article III courts 
and other Article I courts, there is no statutory provision 
related to complaints regarding the conduct or disability of a 
Tax Court Judge, Senior Judge, or Special Trial Judge, although 
they voluntarily agree to follow the rules contained in the 
Code of Conduct for U.S. Judges.\18\
---------------------------------------------------------------------------
    \18\Available at http://www.uscourts.gov/uscourts/RulesAndPolicies/
conduct/vol02a-ch02.pdf. 
---------------------------------------------------------------------------

                           REASONS FOR CHANGE

    To ensure the integrity of the Tax Court as well as the 
public's perception of integrity of the Tax Court, the 
Committee believes that the Tax Court needs a process to permit 
investigation and resolution of complaints about judges. 
Apparently the failure to promulgate such rules is due to 
concerns that the Tax Court lacks statutory authority to do so. 
Accordingly, the Committee wishes to add explicit statutory 
authority to promulgate rules governing the conduct of all 
judges of the Tax Court.

                        EXPLANATION OF PROVISION

    The provision authorizes the Tax Court to prescribe 
procedures for the filing of complaints with respect to the 
conduct of any judge or special trial judge of the Tax Court 
and for the investigation and resolution of such complaints. In 
investigating and taking action with respect to such a 
complaint, the provision authorizes the Tax Court to exercise 
the powers granted to a judicial council under Title 28.

                             EFFECTIVE DATE

    The provision applies to proceedings commenced after the 
date which is 180 days after the date of enactment, and to the 
extent that it is just and practicable, to all proceedings 
pending on such date.

2. Administration, judicial conference, and fees (sec. 202 of the bill; 
       Code sec. 7473; and new secs. 7470 and 7470A of the Code)

                              PRESENT LAW

    Congress established the Tax Court as a court of law under 
Article I with its governing provisions in the Code. However, 
provisions governing most Federal courts are codified in Title 
28 of the United States Code. Congress has, from time to time, 
amended the governing laws of other Federal courts and the laws 
that apply to the Administrative Office of the United States 
Courts relating to administering certain authorities of the 
judiciary.\19\
---------------------------------------------------------------------------
    \19\These authorities are available to Article III courts either 
directly or through the laws enacted for the Administrative Office of 
the United States Courts (AOUSC) under U.S.C. title 28 (see, e.g., 28 
U.S.C. secs. 601, et seq.) and to other Article I courts such as the 
U.S. Court of Appeals for Veterans Claims under 38 U.S.C. sec. 7287.
---------------------------------------------------------------------------
    Federal courts, including Article I courts such as the 
Court of Appeals for Veterans Claims, have express statutory 
authority to conduct an annual judicial conference.\20\ The Tax 
Court has conducted periodic judicial conferences in order to 
consider the business of the Tax Court and to discuss means of 
improving the administration of justice within the Tax Court's 
jurisdiction. The Tax Court's judicial conferences have been 
attended by persons admitted to practice before the Tax Court, 
including representatives of the Internal Revenue Service, the 
Department of Justice, private practitioners, low-income 
taxpayer clinics, and by other persons active in the legal 
profession.
---------------------------------------------------------------------------
    \20\38 U.S.C. sec. 7286.
---------------------------------------------------------------------------
    Federal courts are authorized to deposit certain court fees 
into a special fund of the Treasury to be available to offset 
funds appropriated for the operation and maintenance of the 
courts.\21\ The Tax Court's filing fees are statutorily set at 
``not in excess of $60'' and are covered into the Treasury as 
miscellaneous receipts.\22\
---------------------------------------------------------------------------
    \21\28 U.S.C. secs. 1941(A) and 1931.
    \22\Sec. 7473.
---------------------------------------------------------------------------

                           REASONS FOR CHANGE

    The Committee believes that it would enhance the perceived 
independence of the Tax Court if fees collected by the Tax 
Court were deposited in a special fund for use to offset costs 
of administration of the Tax Court, as other Article I courts 
and all Article III courts do.

                        EXPLANATION OF PROVISION

    The provision amends the Code to provide the Tax Court with 
the same general management, administrative, and expenditure 
authorities that are available to Article III courts and the 
Court of Appeals for Veterans Claims.
    The provision amends the Code to provide the Tax Court with 
express authority to conduct an annual judicial conference and 
charge a reasonable registration fee.
    The provision amends the Code to authorize the Tax Court to 
deposit certain fees into a special fund of the Treasury to be 
available to offset funds appropriated for the operation and 
maintenance of the Tax Court.

                             EFFECTIVE DATE

    The provision is effective on the date of enactment.

 C. Clarification relating to the United States Tax Court (sec. 301 of 
                  the bill and sec. 7441 of the Code)

                              PRESENT LAW

    The Tax Court was created in 1969 as a court of record 
established under Article I of the U.S. Constitution with 
jurisdiction over tax matters as conferred upon it under the 
Code.\23\ It superseded an independent agency of the Executive 
Branch known as the Tax Court of the United States, which 
itself superseded the Board of Tax Appeals.\24\
---------------------------------------------------------------------------
    \23\Sec. 7441.
    \24\The Board of Tax Appeals was created in 1924 to review 
deficiency determinations. In 1942, it was renamed the Tax Court of the 
United States.
---------------------------------------------------------------------------
    As judges of an Article I court, Tax Court judges do not 
have lifetime tenure nor do they enjoy the salary protection 
afforded judges in Article III courts. They are subject to 
removal only for cause, by the President.\25\ The authority to 
remove a judge for cause was the basis for a recent 
unsuccessful challenge to an order of the Tax Court, in which 
the taxpayer invoked the separation of powers doctrine to argue 
that the removal authority is an unconstitutional interference 
of the executive branch with the exercise of judicial powers. 
In rejecting that challenge, the Court of Appeals for the 
District of Columbia held in Kuretski v. Commissioner\26\ that 
the Tax Court is not part of the Article III Judicial Branch 
and is an independent Executive Branch agency, while 
acknowledging that the Tax Court is a ``Court of Law'' for 
purposes of the Appointments Clause.\27\
---------------------------------------------------------------------------
    \25\Sec. 7443(f) permits the President to remove a Tax Court judge 
for inefficiency, neglect of duty, or malfeasance in office, after 
notice and opportunity for a public hearing.
    \26\Kuretski v. Commissioner, 755 F.3d 929 (D.C. Cir. 2014), 
petition for cert. filed (U.S. Nov. 26, 2014) (No. 14-622), available 
at http://www.procedurallytaxing.com/wp-content/uploads/2014/12/
Kuretski-Supreme-Court-Petition.pdf. For an explanation of the status 
of Article I courts in comparison to the Article III judiciary, see, 
Nolan, Andrew and Thompson, Richard M., Congressional Research Service, 
Congressional Power to Create Federal Courts: A Legal Overview (Report 
No. R43746), October 1, 2014, available at http://www.fas.org/sgp/crs/
misc/R43746.pdf.
    \27\Kuretski v. Commissioner, p. 932, distinguishing Freytag v. 
Commissioner, 501 U.S. 868 (1991).
---------------------------------------------------------------------------

                           REASONS FOR CHANGE

    The Committee is concerned that statements in Kuretski v. 
Commissioner may lead the public to question the independence 
of the Tax Court, especially in relation to the Department of 
Treasury or the Internal Revenue Service. The Committee wishes 
to remove any uncertainty caused by Kuretski v. Commissioner, 
and to ensure that there is no appearance of institutional 
bias.

                        EXPLANATION OF PROVISION

    The provision clarifies that the Tax Court is not an agency 
of, and shall be independent of, the Executive Branch.

                             EFFECTIVE DATE

    The provision is effective upon the date of enactment.

                    III. BUDGET EFFECTS OF THE BILL

                         A. Committee Estimates

    In compliance with paragraph 11(a) of rule XXVI of the 
Standing Rules of the Senate, the following statement is made 
concerning the estimated budget effects of the revenue 
provisions of a bill to amend the Internal Revenue Code of 1986 
to improve access and administration of the United States Tax 
Court, as reported.
    The provisions are estimated to reduce Federal fiscal year 
budget receipts by less than $500,000 for the period 2015-2025.

                B. Budget Authority and Tax Expenditures

Budget authority

    In compliance with section 308(a)(1) of the Budget Act, the 
Committee states that no provisions of the bill as reported 
involve new or increased budget authority.

Tax expenditures

    In compliance with section 308(a)(2) of the Budget Act, the 
Committee states that there are no provisions that affect the 
levels of tax expenditures.

            C. Consultation With Congressional Budget Office

    In accordance with section 403 of the Budget Act, the 
Committee advises that the Congressional Budget Office has not 
submitted a statement on the bill. The letter from the 
Congressional Budget Office will be provided separately.

                       IV. VOTES OF THE COMMITTEE

    In compliance with paragraph 7(b) of rule XXVI of the 
Standing Rules of the Senate, the Committee states that, with a 
majority present, a bill to amend the Internal Revenue Code of 
1986 to improve access and administration of the United States 
Tax Court, was ordered favorably reported by voice vote on 
February 11, 2015.

                 V. REGULATORY IMPACT AND OTHER MATTERS

                          A. Regulatory Impact

    Pursuant to paragraph 11(b) of rule XXVI of the Standing 
Rules of the Senate, the Committee makes the following 
statement concerning the regulatory impact that might be 
incurred in carrying out the provisions of the bill.

Impact on individuals and businesses, personal privacy and paperwork

    The bill includes various provisions that improve access 
and administration of the U.S. Tax Court. The provisions of the 
bill are not expected to impose additional administrative 
requirements or regulatory burdens on individuals or 
businesses.
    The provisions of the bill do not impact personal privacy.

                     B. Unfunded Mandates Statement

    This information is provided in accordance with section 423 
of the Unfunded Mandates Reform Act of 1995 (Pub. L. No. 104-
4).
    The Committee has determined that the tax provisions of the 
reported bill do not contain Federal private sector mandates or 
Federal intergovernmental mandates on State, local, or tribal 
governments within the meaning of Public Law 104-4, the 
Unfunded Mandates Reform Act of 1995.

                       C. Tax Complexity Analysis

    Section 4022(b) of the Internal Revenue Service Reform and 
Restructuring Act of 1998 (the ``IRS Reform Act'') requires the 
staff of the Joint Committee on Taxation (in consultation with 
the Internal Revenue Service and the Treasury Department) to 
provide a tax complexity analysis. The complexity analysis is 
required for all legislation reported by the Senate Committee 
on Finance, the House Committee on Ways and Means, or any 
committee of conference if the legislation includes a provision 
that directly or indirectly amends the Internal Revenue Code 
and has widespread applicability to individuals or small 
businesses. The staff of the Joint Committee on Taxation has 
determined that there are no provisions that are of widespread 
applicability to individuals or small businesses.

       VI. CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED

    In the opinion of the Committee, it is necessary in order 
to expedite the business of the Senate, to dispense with the 
requirements of paragraph 12 of rule XXVI of the Standing Rules 
of the Senate (relating to the showing of changes in existing 
law made by the bill as reported by the Committee).

                                  [all]
```