I 
119TH CONGRESS 
2D SESSION 
H. R. 6999 
To amend the Internal Revenue Code of 1986 to repeal the limitation on 
deductions for personal casualty losses and to provide for increased 
taxpayer relief with respect to theft losses involving fraud, deceit, or 
misrepresentation. 
IN THE HOUSE OF REPRESENTATIVES 
JANUARY 9, 2026 
Mr. MILLER of Ohio (for himself and Mr. SUOZZI) introduced the following 
bill; which was referred to the Committee on Ways and Means 
A BILL 
To amend the Internal Revenue Code of 1986 to repeal 
the limitation on deductions for personal casualty losses 
and to provide for increased taxpayer relief with respect 
to theft losses involving fraud, deceit, or misrepresenta-
tion. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Tax Relief for Fraud 
Victims Act’’. 
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SEC. 2. REPEAL OF LIMITATION ON DEDUCTIONS FOR PER-
SONAL CASUALTY LOSSES; INCREASED TAX-
PAYER RELIEF WITH RESPECT TO CERTAIN 
THEFT LOSSES. 
(a) REPEAL OF LIMITATION ON DEDUCTIONS FOR 
PERSONAL CASUALTY LOSSES.—Section 165(h) of the In-
ternal Revenue Code of 1986 is amended by striking para-
graph (5). 
(b) CERTAIN THEFT LOSSES SUSTAINED DURING 
TAXABLE YEAR OF CHOICE; EXTENSION OF PERIOD OF 
LIMITATION FOR CREDIT OR REFUND CLAIMS FOR CER-
TAIN THEFT LOSSES.— 
(1) CERTAIN THEFT LOSSES SUSTAINED DUR-
ING TAXABLE YEAR OF CHOICE.—Section 165(e) of 
such Code is amended to read as follows: 
‘‘(e) THEFT LOSSES.—For purposes of subsection 
(a)— 
‘‘(1) IN GENERAL.—Except as provided in para-
graph (2), any loss arising from theft shall be treat-
ed as sustained during the taxable year in which the 
taxpayer discovers such loss. 
‘‘(2) THEFT
LOSSES
INVOLVING
FRAUD, DE-
CEIT, OR MISREPRESENTATION.—In the case of any 
loss arising from theft involving fraud, deceit, or 
misrepresentation (as defined by the Secretary), the 
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taxpayer may elect to treat such loss as sustained 
during the taxable year in which such loss occurs.’’. 
(2) EXTENSION OF PERIOD OF LIMITATION FOR 
CREDIT OR REFUND CLAIMS FOR CERTAIN THEFT 
LOSSES.—Section 165(h)(4) of such Code is amend-
ed by adding at the end the following new subpara-
graph: 
‘‘(F) PERIOD OF LIMITATION FOR CREDIT 
OR
REFUND
CLAIMS
FOR
THEFT
LOSSES
IN-
VOLVING FRAUD, DECEIT, OR MISREPRESENTA-
TION.—In the case of a claim for credit or re-
fund with respect to a deduction allowed under 
subsection (a) for any loss arising from theft in-
volving fraud, deceit, or misrepresentation— 
‘‘(i) the period of limitation prescribed 
by section 6511(a) for the filing of such 
claim shall be treated as not expiring ear-
lier than the date that is 1 year after the 
date on which the taxpayer discovers such 
loss, and 
‘‘(ii) section 6511(b)(2) shall not 
apply with respect to the filing of such 
claim.’’. 
(c) DISTRIBUTIONS RELATING TO THEFT LOSSES 
INVOLVING FRAUD, DECEIT, OR MISREPRESENTATION.— 
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Section 72(t)(2) of such Code is amended by adding at 
the end the following new subparagraph: 
‘‘(O) DISTRIBUTIONS RELATING TO THEFT 
LOSSES
INVOLVING
FRAUD, DECEIT, OR
MIS-
REPRESENTATION.— 
‘‘(i) IN
GENERAL.—Any distribution 
to the extent it relates to any loss arising 
from theft involving fraud, deceit, or mis-
representation for which a deduction is al-
lowed under section 165(a). 
‘‘(ii) AMOUNT DISTRIBUTED MAY BE 
REPAID.—Rules similar to the rules of sub-
paragraph (H)(v) shall apply with respect 
to an individual who receives a distribution 
to which clause (i) applies, except that sub-
paragraph (H)(v)(I) shall be applied by 
substituting ‘1-year period beginning on 
the day after the date on which the tax-
payer discovers the loss described in sub-
paragraph (O)(i)’ for ‘3-year period begin-
ning on the day after the date on which 
such distribution was received’. 
‘‘(iii) PERIOD
OF
LIMITATION
FOR 
CREDIT OR REFUND CLAIMS.—In the case 
of a claim for credit or refund of the tax 
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imposed by paragraph (1) with respect to 
a distribution described in clause (i)— 
‘‘(I) the period of limitation pre-
scribed by section 6511(a) for the fil-
ing of such claim shall be treated as 
not expiring earlier than the date that 
is 1 year after the date on which the 
taxpayer discovers the loss described 
in clause (i), and 
‘‘(II) section 6511(b)(2) shall not 
apply with respect to the filing of such 
claim.’’. 
(d) CROSS REFERENCE.—Section 6511(i) of such 
Code is amended by adding at the end the following new 
paragraph: 
‘‘(8) For a period of limitations for credit or re-
fund in the case of theft losses involving fraud, de-
ceit, 
or 
misrepresentation, 
see 
sections 
72(t)(2)(O)(iii) and 165(h)(4)(F).’’. 
(e) EFFECTIVE DATES.— 
(1) IN GENERAL.—Except as provided in para-
graph (2), the amendments made by this section 
shall apply to losses sustained in taxable years be-
ginning after December 31, 2025. 
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(2) DISTRIBUTIONS
RELATING
TO
THEFT 
LOSSES INVOLVING FRAUD, DECEIT, OR MISREPRE-
SENTATION.—The amendment made by subsection 
(c) shall apply to distributions made after December 
31, 2025. 
Æ 
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