126
‘‘(A) ensure that such return and return 
information is kept confidential, 
‘‘(B) use such return and return informa-
tion only for the purpose for which it was re-
quested, and 
‘‘(C) not disclose such return and return 
information except to accomplish the purpose 
for which it was requested, unless a separate 
consent from the taxpayer is obtained. 
‘‘(4) REQUIREMENTS
FOR
FORM
PRESCRIBED 
BY SECRETARY.—For purposes of this subsection, 
the Secretary shall prescribe a form for requests and 
consents which shall— 
‘‘(A) contain a warning, prominently dis-
played, informing the taxpayer that the form 
should not be signed unless it is completed, 
‘‘(B) state that if the taxpayer believes 
there is an attempt to coerce him to sign an in-
complete or blank form, the taxpayer should re-
port the matter to the Treasury Inspector Gen-
eral for Tax Administration, and 
‘‘(C) contain the address and telephone 
number of the Treasury Inspector General for 
Tax Administration.’’.
127
(b) REPORT.—Not later than 18 months after the 
date of the enactment of this Act, the Treasury Inspector 
General for Tax Administration shall submit a report to 
the Congress on compliance with the designation and cer-
tification requirements applicable to requests for or con-
sent to disclosure of returns and return information under 
section 6103(c) of the Internal Revenue Code of 1986, as 
amended by subsection (a). Such report shall—
(1) evaluate (on the basis of random sampling) 
whether—
(A) the amendment made by subsection (a) 
is achieving the purposes of this section; 
(B) requesters and submitters for such dis-
closure are continuing to evade the purposes of 
this section and, if so, how; and 
(C) the sanctions for violations of such re-
quirements are adequate; and 
(2) include such recommendations that the 
Treasury Inspector General for Tax Administration 
considers necessary or appropriate to better achieve 
the purposes of this section. 
(c) CONFORMING AMENDMENTS.—
(1) Section 6103(c) is amended by striking 
‘‘TAXPAYER.—The Secretary’’ and inserting ‘‘TAX-
PAYER.—
128
‘‘(1) IN GENERAL.—The Secretary’’. 
(2) Section 7213(a)(1) is amended by striking 
‘‘section 6103(n)’’ and inserting ‘‘subsections (c) 
and (n) of section 6103’’. 
(3) Section 7213A(a)(1)(B) is amended by 
striking ‘‘subsection (l)(18) or (n) of section 6103’’ 
and inserting ‘‘subsection (c), (l)(18), or (n) of sec-
tion 6103’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to requests and consents made 
after 3 months after the date of the enactment of this 
Act. 
SEC. 347. NOTICE TO TAXPAYER CONCERNING ADMINIS-
TRATIVE DETERMINATION OF BROWSING; AN-
NUAL REPORT. 
(a) NOTICE TO TAXPAYER.—Subsection (e) of section 
7431 (relating to notification of unlawful inspection and 
disclosure) is amended by adding at the end the following: 
‘‘The Secretary shall also notify such taxpayer if the 
Treasury Inspector General for Tax Administration sub-
stantiates that such taxpayer’s return or return informa-
tion was inspected or disclosed in violation of any of the 
provisions specified in paragraph (1), (2), or (3).’’.
129
(b) REPORTS.—Subsection (p) of section 6103 (relat-
ing to procedure and recordkeeping), is amended by add-
ing at the end the following new paragraph: 
‘‘(10) REPORT ON UNAUTHORIZED DISCLOSURE 
AND INSPECTION.—As part of the report required by 
paragraph (3)(C) for each calendar year, the Sec-
retary shall furnish information regarding the unau-
thorized disclosure and inspection of returns and re-
turn information, including the number, status, and 
results of—
‘‘(A) administrative investigations, 
‘‘(B) civil lawsuits brought under section 
7431 (including the amounts for which such 
lawsuits were settled and the amounts of dam-
ages awarded), and 
‘‘(C) criminal prosecutions.’’. 
(c) EFFECTIVE DATE.—
(1) NOTICE.—The amendment made by sub-
section (a) shall apply to determinations made after 
the date of the enactment of this Act. 
(2) REPORTS.—The amendment made by sub-
section (b) shall apply to calendar years ending after 
the date of the enactment of this Act.
130
SEC. 348. EXPANDED DISCLOSURE IN EMERGENCY CIR-
CUMSTANCES. 
(a) IN GENERAL.—Section 6103(i)(3)(B) (relating to 
danger of death or physical injury) is amended by striking 
‘‘or State’’ and inserting ‘‘, State, or local’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect on the date of the enactment 
of this Act. 
SEC. 349. DISCLOSURE OF TAXPAYER IDENTITY FOR TAX 
REFUND PURPOSES. 
(a) IN GENERAL.—Paragraph (1) of section 6103(m) 
(relating to disclosure of taxpayer identity information) is 
amended by striking ‘‘and other media’’ and by inserting 
‘‘, other media, and through any other means of mass 
communication,’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall take effect on the date of the enactment 
of this Act. 
SEC. 350. DISCLOSURE TO STATE OFFICIALS OF PROPOSED 
ACTIONS RELATED TO SECTION 501(c)(3) OR-
GANIZATIONS. 
(a) IN GENERAL.—Subsection (c) of section 6104 is 
amended by striking paragraph (2) and inserting the fol-
lowing new paragraphs: 
‘‘(2) DISCLOSURE OF PROPOSED ACTIONS.—
131
‘‘(A) SPECIFIC
NOTIFICATIONS.—In the 
case of an organization to which paragraph (1) 
applies, the Secretary may disclose to the ap-
propriate State officer—
‘‘(i) a notice of proposed refusal to 
recognize such organization as an organi-
zation described in section 501(c)(3) or a 
notice of proposed revocation of such orga-
nization’s recognition as an organization 
exempt from taxation, 
‘‘(ii) the issuance of a letter of pro-
posed deficiency of tax imposed under sec-
tion 507 or chapter 41 or 42, and 
‘‘(iii) the names, addresses, and tax-
payer identification numbers of organiza-
tions that have applied for recognition as 
organizations 
described 
in 
section 
501(c)(3). 
‘‘(B) ADDITIONAL DISCLOSURES.—Returns 
and return information of organizations with 
respect to which information is disclosed under 
subparagraph (A) may be made available for in-
spection by or disclosed to an appropriate State 
officer.
132
‘‘(C) PROCEDURES FOR DISCLOSURE.—In-
formation may be inspected or disclosed under 
subparagraph (A) or (B) only—
‘‘(i) upon written request by an ap-
propriate State officer, and 
‘‘(ii) for the purpose of, and only to 
the extent necessary in, the administration 
of State laws regulating such organiza-
tions. 
Such information may only be inspected by or 
disclosed to a person other than the appropriate 
State officer if such person is an officer or em-
ployee of the State and is designated by the ap-
propriate State officer to receive the returns or 
return information under this paragraph on be-
half of the appropriate State officer. 
‘‘(D) DISCLOSURES OTHER THAN BY RE-
QUEST.—The Secretary may make available for 
inspection or disclose returns and return infor-
mation of an organization to which paragraph 
(1) applies to an appropriate State officer of 
any State if the Secretary determines that such 
inspection or disclosure may facilitate the reso-
lution of State or Federal issues relating to the 
tax-exempt status of such organization.
133
‘‘(3) USE IN ADMINISTRATIVE AND JUDICIAL 
CIVIL PROCEEDINGS.—Returns and return informa-
tion disclosed pursuant to this subsection may be 
disclosed in administrative and judicial civil pro-
ceedings pertaining to the enforcement of State laws 
regulating such organizations in a manner pre-
scribed by the Secretary similar to that for tax ad-
ministration proceedings under section 6103(h)(4). 
‘‘(4) NO
DISCLOSURE
IF
IMPAIRMENT.—Re-
turns and return information shall not be disclosed 
under this subsection, or in any proceeding described 
in paragraph (3), to the extent that the Secretary 
determines that such disclosure would seriously im-
pair Federal tax administration. 
‘‘(5) DEFINITIONS.—For purposes of this sub-
section—
‘‘(A) RETURN
AND
RETURN
INFORMA-
TION.—The terms ‘return’ and ‘return informa-
tion’ have the respective meanings given to such 
terms by section 6103(b). 
‘‘(B) APPROPRIATE STATE OFFICER.—The 
term ‘appropriate State officer’ means—
‘‘(i) the State attorney general, or
134
‘‘(ii) any other State official charged 
with overseeing organizations of the type 
described in section 501(c)(3).’’. 
(b) CONFORMING AMENDMENTS.—
(1) Subparagraph (A) of section 6103(p)(3) is 
amended by inserting ‘‘and section 6104(c)’’ after 
‘‘section’’ in the first sentence. 
(2) Paragraph (4) of section 6103(p) is amend-
ed—
(A) in the matter preceding subparagraph 
(A), by inserting ‘‘, or any appropriate State of-
ficer (as defined in section 6104(c)),’’ before 
‘‘or any other person’’, 
(B) in subparagraph (F)(i), by inserting 
‘‘or any appropriate State officer (as defined in 
section 6104(c)),’’ before ‘‘or any other per-
son’’, and 
(C) in the matter following subparagraph 
(F), by inserting ‘‘, an appropriate State officer 
(as defined in section 6104(c)),’’ after ‘‘includ-
ing an agency’’ each place it appears. 
(3) Paragraph (2) of section 7213(a) is amend-
ed by inserting ‘‘or under section 6104(c)’’ after 
‘‘6103’’.
135
(4) Paragraph (2) of section 7213A(a) is 
amended by inserting ‘‘or 6104(c)’’ after ‘‘6103’’. 
(5) Paragraph (2) of section 7431(a) is amend-
ed by inserting ‘‘(including any disclosure in viola-
tion of section 6104(c))’’ after ‘‘6103’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall take effect on the date of the enactment 
of this Act but shall not apply to requests made before 
such date.
SEC. 351. CONFIDENTIALITY OF TAXPAYER COMMUNICA-
TIONS WITH THE OFFICE OF THE TAXPAYER 
ADVOCATE. 
(a) IN GENERAL.—Subsection (c) of section 7803 is 
amended by adding at the end the following new para-
graph: 
‘‘(5) CONFIDENTIALITY OF TAXPAYER INFOR-
MATION.—
‘‘(A) IN GENERAL.—To the extent author-
ized by the National Taxpayer Advocate or pur-
suant to guidance issued under subparagraph 
(B), any officer or employee of the Office of the 
Taxpayer Advocate may withhold from the In-
ternal Revenue Service and the Department of 
Justice any information provided by, or regard-
ing contact with, any taxpayer.