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disputed issues (other than documents provided 
by the taxpayer to the Internal Revenue Serv-
ice) not later than 10 days before the date of 
such conference. 
‘‘(B) TAXPAYER ELECTION TO EXPEDITE 
CONFERENCE.—If the taxpayer so elects, sub-
paragraph (A) shall be applied by substituting 
‘the date of such conference’ for ‘10 days before 
the date of such conference’. 
‘‘(C) SPECIFIED
TAXPAYER.—For pur-
poses of this paragraph— 
‘‘(i) IN GENERAL.—The term ‘speci-
fied taxpayer’ means— 
‘‘(I) in the case of any taxpayer 
who is a natural person, a taxpayer 
whose adjusted gross income does not 
exceed $400,000 for the taxable year 
to which the dispute relates, and 
‘‘(II) in the case of any other 
taxpayer, a taxpayer whose gross re-
ceipts do not exceed $5 million for the 
taxable year to which the dispute re-
lates. 
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‘‘(ii) 
AGGREGATION
RULE.—Rules 
similar to the rules of section 448(c)(2) 
shall apply for purposes of clause (i)(II).’’. 
(b) CONFORMING AMENDMENTS.— 
(1) The following provisions are each amended 
by striking ‘‘Internal Revenue Service Office of Ap-
peals’’ and inserting ‘‘Internal Revenue Service 
Independent Office of Appeals’’: 
(A) Section 6015(c)(4)(B)(ii)(I). 
(B) Section 6320(b)(1). 
(C) Subsections (b)(1) and (d)(3) of sec-
tion 6330. 
(D) Section 6603(d)(3)(B). 
(E) Section 6621(c)(2)(A)(i). 
(F) Section 7122(e)(2). 
(G) Subsections (a), (b)(1), (b)(2), and 
(c)(1) of section 7123. 
(H) Subsections (c)(7)(B)(i) and (g)(2)(A) 
of section 7430. 
(I) Section 7522(b)(3). 
(J) Section 7612(c)(2)(A). 
(2) Section 7430(c)(2) is amended by striking 
‘‘Internal Revenue Service Office of Appeals’’ each 
place it appears and inserting ‘‘Internal Revenue 
Service Independent Office of Appeals’’. 
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(3) The heading of section 6330(d)(3) is 
amended by inserting ‘‘INDEPENDENT’’ after ‘‘IRS’’. 
(c) OTHER REFERENCES.—Any reference in any pro-
vision of law, or regulation or other guidance, to the Inter-
nal Revenue Service Office of Appeals shall be treated as 
a reference to the Internal Revenue Service Independent 
Office of Appeals. 
(d) SAVINGS PROVISIONS.—Rules similar to the rules 
of paragraphs (2) through (6) of section 1001(b) of the 
Internal Revenue Service Restructuring and Reform Act 
of 1998 shall apply for purposes of this section (and the 
amendments made by this section). 
(e) EFFECTIVE DATE.— 
(1) IN
GENERAL.—Except as otherwise pro-
vided in this subsection, the amendments made by 
this section shall take effect on the date of the en-
actment of this Act. 
(2) 
ACCESS
TO
CASE
FILES.—Section 
7803(e)(7) of the Internal Revenue Code of 1986, as 
added by subsection (a), shall apply to conferences 
occurring after the date which is 1 year after the 
date of the enactment of this Act. 
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Subtitle B—Improved Service 
SEC. 1101. COMPREHENSIVE CUSTOMER SERVICE STRAT-
EGY. 
(a) IN GENERAL.—Not later than the date which is 
1 year after the date of the enactment of this Act, the 
Secretary of the Treasury (or the Secretary’s delegate) 
shall submit to Congress a written comprehensive cus-
tomer service strategy for the Internal Revenue Service. 
Such strategy shall include— 
(1) a plan to provide assistance to taxpayers 
that is secure, designed to meet reasonable taxpayer 
expectations, and adopts appropriate best practices 
of customer service provided in the private sector, 
including online services, telephone call back serv-
ices, and training of employees providing customer 
services; 
(2) a thorough assessment of the services that 
the Internal Revenue Service can co-locate with 
other Federal services or offer as self-service op-
tions; 
(3) proposals to improve Internal Revenue Serv-
ice customer service in the short term (the current 
and following fiscal year), medium term (approxi-
mately 3 to 5 fiscal years), and long term (approxi-
mately 10 fiscal years); 
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(4) a plan to update guidance and training ma-
terials for customer service employees of the Internal 
Revenue Service, including the Internal Revenue 
Manual, to reflect such strategy; and 
(5) identified metrics and benchmarks for quan-
titatively measuring the progress of the Internal 
Revenue Service in implementing such strategy. 
(b) UPDATED GUIDANCE
AND TRAINING MATE-
RIALS.—Not later than 2 years after the date of the enact-
ment of this Act, the Secretary of the Treasury (or the 
Secretary’s delegate) shall make available the updated 
guidance and training materials described in subsection 
(a)(4) (including the Internal Revenue Manual). Such up-
dated guidance and training materials (including the In-
ternal Revenue Manual) shall be written in a manner so 
as to be easily understood by customer service employees 
of the Internal Revenue Service and shall provide clear 
instructions. 
SEC. 1102. LOW-INCOME EXCEPTION FOR PAYMENTS OTH-
ERWISE REQUIRED IN CONNECTION WITH A 
SUBMISSION OF AN OFFER-IN-COMPROMISE. 
(a) IN GENERAL.—Section 7122(c) is amended by 
adding at the end the following new paragraph: 
‘‘(3) 
EXCEPTION
FOR
LOW-INCOME
TAX-
PAYERS.—Paragraph (1), and any user fee otherwise 
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required in connection with the submission of an 
offer-in-compromise, shall not apply to any offer-in- 
compromise with respect to a taxpayer who is an in-
dividual with adjusted gross income, as determined 
for the most recent taxable year for which such in-
formation is available, which does not exceed 250 
percent of the applicable poverty level (as deter-
mined by the Secretary).’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to offers-in-compromise submitted 
after the date of the enactment of this Act. 
Subtitle C—Sensible Enforcement 
SEC. 1201. INTERNAL REVENUE SERVICE SEIZURE RE-
QUIREMENTS 
WITH 
RESPECT 
TO 
STRUC-
TURING TRANSACTIONS. 
Section 5317(c)(2) of title 31, United States Code, 
is amended— 
(1) by striking ‘‘Any property’’ and inserting 
the following: 
‘‘(A) IN GENERAL.—Any property’’; and 
(2) by adding at the end the following: 
‘‘(B) INTERNAL
REVENUE
SERVICE
SEI-
ZURE
REQUIREMENTS
WITH
RESPECT
TO 
STRUCTURING TRANSACTIONS.— 
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‘‘(i) PROPERTY DERIVED FROM AN IL-
LEGAL
SOURCE.—Property may only be 
seized by the Internal Revenue Service 
pursuant to subparagraph (A) by reason of 
a claimed violation of section 5324 if the 
property to be seized was derived from an 
illegal source or the funds were structured 
for the purpose of concealing the violation 
of a criminal law or regulation other than 
section 5324. 
‘‘(ii) NOTICE.—Not later than 30 
days after property is seized by the Inter-
nal Revenue Service pursuant to subpara-
graph (A), the Internal Revenue Service 
shall— 
‘‘(I) make a good faith effort to 
find all persons with an ownership in-
terest in such property; and 
‘‘(II) provide each such person so 
found with a notice of the seizure and 
of the person’s rights under clause 
(iv). 
‘‘(iii) EXTENSION OF NOTICE UNDER 
CERTAIN
CIRCUMSTANCES.—The Internal 
Revenue Service may apply to a court of 
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competent jurisdiction for one 30-day ex-
tension of the notice requirement under 
clause (ii) if the Internal Revenue Service 
can establish probable cause of an immi-
nent threat to national security or personal 
safety necessitating such extension. 
‘‘(iv) POST-SEIZURE
HEARING.—If a 
person with an ownership interest in prop-
erty seized pursuant to subparagraph (A) 
by the Internal Revenue Service requests a 
hearing by a court of competent jurisdic-
tion within 30 days after the date on which 
notice is provided under subclause (ii), 
such property shall be returned unless the 
court holds an adversarial hearing and 
finds within 30 days of such request (or 
such longer period as the court may pro-
vide, but only on request of an interested 
party) that there is probable cause to be-
lieve that there is a violation of section 
5324 involving such property and probable 
cause to believe that the property to be 
seized was derived from an illegal source or 
the funds were structured for the purpose 
of concealing the violation of a criminal 
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law or regulation other than section 
5324.’’. 
SEC. 1202. EXCLUSION OF INTEREST RECEIVED IN ACTION 
TO RECOVER PROPERTY SEIZED BY THE IN-
TERNAL 
REVENUE 
SERVICE 
BASED 
ON 
STRUCTURING TRANSACTION. 
(a) IN GENERAL.—Part III of subchapter B of chap-
ter 1 is amended by inserting before section 140 the fol-
lowing new section: 
‘‘SEC. 139H. INTEREST RECEIVED IN ACTION TO RECOVER 
PROPERTY SEIZED BY THE INTERNAL REV-
ENUE SERVICE BASED ON STRUCTURING 
TRANSACTION. 
‘‘Gross income shall not include any interest received 
from the Federal Government in connection with an action 
to recover property seized by the Internal Revenue Service 
pursuant to section 5317(c)(2) of title 31, United States 
Code, by reason of a claimed violation of section 5324 of 
such title.’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for part III of subchapter B of chapter 1 is amended by 
inserting before the item relating to section 140 the fol-
lowing new item: 
‘‘Sec. 139H. Interest received in action to recover property seized by the Inter-
nal Revenue Service based on structuring transaction.’’. 
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(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to interest received on or after the 
date of the enactment of this Act. 
SEC. 1203. CLARIFICATION OF EQUITABLE RELIEF FROM 
JOINT LIABILITY. 
(a) IN GENERAL.—Section 6015 is amended— 
(1) in subsection (e), by adding at the end the 
following new paragraph: 
‘‘(7) STANDARD AND SCOPE OF REVIEW.—Any 
review of a determination made under this section 
shall be reviewed de novo by the Tax Court and shall 
be based upon— 
‘‘(A) the administrative record established 
at the time of the determination, and 
‘‘(B) any additional newly discovered or 
previously unavailable evidence.’’; and 
(2) by amending subsection (f) to read as fol-
lows: 
‘‘(f) EQUITABLE RELIEF.— 
‘‘(1) IN
GENERAL.—Under procedures pre-
scribed by the Secretary, if— 
‘‘(A) taking into account all the facts and 
circumstances, it is inequitable to hold the indi-
vidual liable for any unpaid tax or any defi-
ciency (or any portion of either), and 
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‘‘(B) relief is not available to such indi-
vidual under subsection (b) or (c), 
the Secretary may relieve such individual of such li-
ability. 
‘‘(2) LIMITATION.—A request for equitable re-
lief under this subsection may be made with respect 
to any portion of any liability that— 
‘‘(A) has not been paid, provided that such 
request is made before the expiration of the ap-
plicable period of limitation under section 6502, 
or 
‘‘(B) has been paid, provided that such re-
quest is made during the period in which the 
individual could submit a timely claim for re-
fund or credit of such payment.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to petitions or requests filed or 
pending on or after the date of the enactment of this Act. 
SEC. 1204. MODIFICATION OF PROCEDURES FOR ISSUANCE 
OF THIRD-PARTY SUMMONS. 
(a) IN GENERAL.—Section 7609(f) is amended by 
adding at the end the following flush sentence: 
‘‘The Secretary shall not issue any summons described in 
the preceding sentence unless the information sought to 
be obtained is narrowly tailored to information that per-
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tains to the failure (or potential failure) of the person or 
group or class of persons referred to in paragraph (2) to 
comply with one or more provisions of the internal revenue 
law which have been identified for purposes of such para-
graph.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to summonses served after the date 
that is 45 days after the date of the enactment of this 
Act. 
SEC. 1205. PRIVATE DEBT COLLECTION AND SPECIAL COM-
PLIANCE PERSONNEL PROGRAM. 
(a) CERTAIN TAX RECEIVABLES NOT ELIGIBLE FOR 
COLLECTION UNDER TAX COLLECTION CONTRACTS.— 
Section 6306(d)(3) is amended by striking ‘‘or’’ at the end 
of subparagraph (C) and by inserting after subparagraph 
(D) the following new subparagraphs: 
‘‘(E) a taxpayer substantially all of whose 
income consists of disability insurance benefits 
under section 223 of the Social Security Act or 
supplemental security income benefits under 
title XVI of the Social Security Act (including 
supplemental security income benefits of the 
type described in section 1616 of such Act or 
section 212 of Public Law 93–66), or 
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‘‘(F) a taxpayer who is an individual with 
adjusted gross income, as determined for the 
most recent taxable year for which such infor-
mation is available, which does not exceed 200 
percent of the applicable poverty level (as deter-
mined by the Secretary),’’. 
(b) DETERMINATION
OF INACTIVE TAX RECEIV-
ABLES ELIGIBLE FOR COLLECTION UNDER TAX COLLEC-
TION CONTRACTS.—Section 6306(c)(2)(A)(ii) is amended 
by striking ‘‘more than 1⁄3 of the period of the applicable 
statute of limitation has lapsed’’ and inserting ‘‘more than 
2 years has passed since assessment’’. 
(c) MAXIMUM LENGTH OF INSTALLMENT AGREE-
MENTS
OFFERED
UNDER
TAX
COLLECTION
CON-
TRACTS.—Section 6306(b)(1)(B) is amended by striking 
‘‘5 years’’ and inserting ‘‘7 years’’. 
(d) CLARIFICATION THAT SPECIAL COMPLIANCE 
PERSONNEL PROGRAM ACCOUNT MAY BE USED
FOR 
PROGRAM COSTS.— 
(1) IN GENERAL.—Section 6307(b) is amend-
ed— 
(A) in paragraph (2), by striking all that 
follows ‘‘under such program’’ and inserting a 
period, and 
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(B) in paragraph (3), by striking all that 
follows ‘‘out of such account’’ and inserting 
‘‘for other than program costs.’’. 
(2) COMMUNICATIONS, SOFTWARE, AND TECH-
NOLOGY COSTS TREATED AS PROGRAM COSTS.—Sec-
tion 6307(d)(2)(B) is amended by striking ‘‘tele-
communications’’ and inserting ‘‘communications, 
software, technology’’. 
(3) 
CONFORMING
AMENDMENT.—Section 
6307(d)(2) is amended by striking ‘‘and’’ at the end 
of subparagraph (A), by striking the period at the 
end of subparagraph (B) and inserting ‘‘, and’’, and 
by inserting after subparagraph (B) the following 
new subparagraph: 
‘‘(C) reimbursement of the Internal Rev-
enue Service or other government agencies for 
the cost of administering the qualified tax col-
lection program under section 6306.’’. 
(e) EFFECTIVE DATES.— 
(1) IN
GENERAL.—Except as otherwise pro-
vided in this subsection, the amendments made by 
this section shall apply to tax receivables identified 
by the Secretary (or the Secretary’s delegate) after 
December 31, 2020. 
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(2) 
MAXIMUM
LENGTH
OF
INSTALLMENT 
AGREEMENTS.—The amendment made by subsection 
(c) shall apply to contracts entered into after the 
date of the enactment of this Act. 
(3) USE OF SPECIAL COMPLIANCE PERSONNEL 
PROGRAM ACCOUNT.—The amendment made by sub-
section (d) shall apply to amounts expended from 
the special compliance personnel program account 
after the date of the enactment of this Act. 
SEC. 1206. REFORM OF NOTICE OF CONTACT OF THIRD 
PARTIES. 
(a) IN GENERAL.—Section 7602(c)(1) is amended to 
read as follows: 
‘‘(1) GENERAL
NOTICE.—An officer or em-
ployee of the Internal Revenue Service may not con-
tact any person other than the taxpayer with respect 
to the determination or collection of the tax liability 
of such taxpayer unless such contact occurs during 
a period (not greater than 1 year) which is specified 
in a notice which— 
‘‘(A) informs the taxpayer that contacts 
with persons other than the taxpayer are in-
tended to be made during such period, and 
‘‘(B) except as otherwise provided by the 
Secretary, is provided to the taxpayer not later 
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than 45 days before the beginning of such pe-
riod. 
Nothing in the preceding sentence shall prevent the 
issuance of notices to the same taxpayer with respect 
to the same tax liability with periods specified there-
in that, in the aggregate, exceed 1 year. A notice 
shall not be issued under this paragraph unless 
there is an intent at the time such notice is issued 
to contact persons other than the taxpayer during 
the period specified in such notice. The preceding 
sentence shall not prevent the issuance of a notice 
if the requirement of such sentence is met on the 
basis of the assumption that the information sought 
to be obtained by such contact will not be obtained 
by other means before such contact.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to notices provided, and contacts 
of persons made, after the date which is 45 days after 
the date of the enactment of this Act. 
SEC. 1207. MODIFICATION OF AUTHORITY TO ISSUE DES-
IGNATED SUMMONS. 
(a) IN GENERAL.—Paragraph (1) of section 6503(j) 
is amended by striking ‘‘coordinated examination pro-
gram’’ and inserting ‘‘coordinated industry case pro-
gram’’. 
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(b) REQUIREMENTS FOR SUMMONS.—Clause (i) of 
section 6503(j)(2)(A) is amended to read as follows: 
‘‘(i) the issuance of such summons is 
preceded by a review and written approval 
of such issuance by the Commissioner of 
the relevant operating division of the Inter-
nal Revenue Service and the Chief Counsel 
which— 
‘‘(I) states facts clearly estab-
lishing that the Secretary has made 
reasonable requests for the informa-
tion that is the subject of the sum-
mons, and 
‘‘(II) is attached to such sum-
mons,’’. 
(c) ESTABLISHMENT THAT REASONABLE REQUESTS 
FOR INFORMATION WERE MADE.—Subsection (j) of sec-
tion 6503 is amended by adding at the end the following 
new paragraph: 
‘‘(4) ESTABLISHMENT THAT REASONABLE RE-
QUESTS FOR INFORMATION WERE MADE.—In any 
court proceeding described in paragraph (3), the 
Secretary shall establish that reasonable requests 
were made for the information that is the subject of 
the summons.’’. 
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