I 
113TH CONGRESS 
1ST SESSION H. R. 3479 
To provide a taxpayer bill of rights for small businesses. 
IN THE HOUSE OF REPRESENTATIVES 
NOVEMBER 13, 2013 
Mr. THORNBERRY
(for himself, Mr. SESSIONS, Mr. NUGENT, Mr. 
HUELSKAMP, Mr. FARENTHOLD, and Mr. BENTIVOLIO) introduced the 
following bill; which was referred to the Committee on Ways and Means 
A BILL 
To provide a taxpayer bill of rights for small businesses. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE; TABLE OF CONTENTS. 
(a) SHORT TITLE.—This Act may be cited as the 
‘‘Small Business Taxpayer Bill of Rights Act of 2013’’. 
(b) TABLE OF CONTENTS.—The table of contents of 
this Act is as follows: 
Sec. 1. Short title; table of contents. 
Sec. 2. Modification of standards for awarding of costs and certain fees. 
Sec. 3. Civil damages allowed for reckless or intentional disregard of Internal 
Revenue laws. 
Sec. 4. Modifications relating to certain offenses by officers and employees in 
connection with revenue laws. 
Sec. 5. Modifications relating to civil damages for unauthorized inspection or 
disclosure of returns and return information. 
Sec. 6. Interest abatement reviews. 
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Sec. 7. Ban on ex parte discussions. 
Sec. 8. Alternative dispute resolution procedures. 
Sec. 9. Extension of time for contesting IRS levy. 
Sec. 10. Waiver of installment agreement fee. 
Sec. 11. Suspension of running of period for filing petition of spousal relief and 
collection cases. 
Sec. 12. Venue for appeal of spousal relief and collection cases. 
Sec. 13. Increase in monetary penalties for certain unauthorized disclosures of 
information. 
Sec. 14. De novo tax court review of claims for equitable innocent spouse relief. 
Sec. 15. Ban on raising new issues on appeal. 
SEC. 2. MODIFICATION OF STANDARDS FOR AWARDING OF 
COSTS AND CERTAIN FEES. 
(a) SMALL BUSINESSES ELIGIBLE WITHOUT RE-
GARD TO NET WORTH.—Subparagraph (D) of section 
7430(c)(4) of the Internal Revenue Code of 1986 is 
amended by striking ‘‘and’’ at the end of clause (i), by 
striking the period at the end of clause (ii) and inserting 
‘‘and’’, and by adding at the end the following new clause: 
‘‘(iii) in the case of an eligible small 
business, the net worth limitation in clause 
(ii) of such section shall not apply.’’. 
(b) ELIGIBLE SMALL BUSINESS.—Paragraph (4) of 
section 7430(c) of the Internal Revenue Code of 1986 is 
amended by adding at the end the following new subpara-
graph: 
‘‘(F) ELIGIBLE
SMALL
BUSINESS.—For 
purposes of subparagraph (D)(iii), the term ‘eli-
gible small business’ means, with respect to any 
proceeding commenced in a taxable year— 
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‘‘(i) a corporation the stock of which 
is not publicly traded, 
‘‘(ii) a partnership, or 
‘‘(iii) a sole proprietorship, 
if the average annual gross receipts of such cor-
poration, partnership, or sole proprietorship for 
the 3-taxable-year period preceding such taxable 
year does not exceed $50,000,000. For pur-
poses of applying the test under the preceding 
sentence, rules similar to the rules of para-
graphs (2) and (3) of section 448(c) shall 
apply.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to proceedings commenced after 
the date of the enactment of this Act. 
SEC. 3. CIVIL DAMAGES ALLOWED FOR RECKLESS OR IN-
TENTIONAL DISREGARD OF INTERNAL REV-
ENUE LAWS. 
(a) INCREASE IN AMOUNT OF DAMAGES.—Section 
7433(b) of the Internal Revenue Code of 1986 is amended 
by striking ‘‘$1,000,000 ($100,000, in the case of neg-
ligence)’’ and inserting ‘‘$3,000,000 ($300,000, in the 
case of negligence)’’. 
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(b) EXTENSION OF TIME TO BRING ACTION.—Sec-
tion 7433(d)(3) of the Internal Revenue Code of 1986 is 
amended by striking ‘‘2 years’’ and inserting ‘‘5 years’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to actions of employees of the In-
ternal Revenue Service after the date of the enactment 
of this Act. 
SEC. 4. MODIFICATIONS RELATING TO CERTAIN OFFENSES 
BY OFFICERS AND EMPLOYEES IN CONNEC-
TION WITH REVENUE LAWS. 
(a) INCREASE IN PENALTY.—Section 7214 of the In-
ternal Revenue Code of 1986 is amended— 
(1) by striking ‘‘$10,000’’ in subsection (a) and 
inserting ‘‘$25,000’’, and 
(2) by striking ‘‘$5,000’’ in subsection (b) and 
inserting ‘‘$10,000’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall take effect on the date of the enactment 
of this Act. 
SEC. 5. MODIFICATIONS RELATING TO CIVIL DAMAGES FOR 
UNAUTHORIZED 
INSPECTION 
OR 
DISCLO-
SURE OF RETURNS AND RETURN INFORMA-
TION. 
(a) INCREASE IN AMOUNT OF DAMAGES.—Subpara-
graph (A) of section 7431(c)(1) of the Internal Revenue 
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Code of 1986 is amended by striking ‘‘$1,000’’ and insert-
ing ‘‘$10,000’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to inspections and disclosure occur-
ring on and after the date of the enactment of this Act. 
SEC. 6. INTEREST ABATEMENT REVIEWS. 
(a) FILING PERIOD
FOR INTEREST ABATEMENT 
CASES.— 
(1) IN
GENERAL.—Subsection (h) of section 
6404 of the Internal Revenue Code of 1986 is 
amended— 
(A) by striking ‘‘REVIEW OF DENIAL’’ in 
the heading and inserting ‘‘JUDICIAL REVIEW’’, 
and 
(B) by striking ‘‘ ‘if such action is 
brought’ ’’ and all that follows in paragraph (1) 
and inserting ‘‘if such action is brought— 
‘‘(A) at any time after the earlier of— 
‘‘(i) the date of the mailing of the 
Secretary’s final determination not to 
abate such interest, or 
‘‘(ii) the date which is 180 days after 
the date of the filing with the Secretary (in 
such form as the Secretary may prescribe) 
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of a claim for abatement under this sec-
tion, and 
‘‘(B) not later than the date which is 180 
days after the date described in subparagraph 
(A)(i).’’. 
(2) EFFECTIVE DATE.—The amendments made 
by this subsection shall apply to claims for abate-
ment of interest filed with the Secretary after the 
date of the enactment of this Act. 
(b) SMALL TAX CASE ELECTION
FOR INTEREST 
ABATEMENT CASES.— 
(1) IN
GENERAL.—Subsection (f) of section 
7463 of the Internal Revenue Code of 1986 is 
amended— 
(A) by striking ‘‘and’’ at the end of para-
graph (1), 
(B) by striking the period at the end of 
paragraph (2) and inserting ‘‘, and’’, and 
(C) by adding at the end the following new 
paragraph: 
‘‘(3) a petition to the Tax court under section 
6404(h) in which the amount of interest abatement 
sought does not exceed $50,000.’’. 
(2) EFFECTIVE DATE.—The amendments made 
by this subsection shall apply to— 
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(A) cases pending as of the day after the 
date of the enactment of this Act, and 
(B) cases commenced after such date of 
enactment. 
SEC. 7. BAN ON EX PARTE DISCUSSIONS. 
(a) 
IN
GENERAL.—Notwithstanding 
section 
1001(a)(4) of the Internal Revenue Service Restructuring 
and Reform Act of 1998, the Internal Revenue Service 
shall prohibit any ex parte communications between offi-
cers in the Internal Revenue Service Office of Appeals and 
other Internal Revenue Service employees with respect to 
any matter pending before such officers. 
(b) TERMINATION
OF
EMPLOYMENT
FOR
MIS-
CONDUCT.—Subject to subsection (c), the Commissioner 
of Internal Revenue shall terminate the employment of 
any employee of the Internal Revenue Service if there is 
a final administrative or judicial determination that such 
employee committed any act or omission prohibited under 
subsection (a) in the performance of the employee’s official 
duties. Such termination shall be a removal for cause on 
charges of misconduct. 
(c) DETERMINATION OF COMMISSIONER.— 
(1) IN GENERAL.—The Commissioner of Inter-
nal Revenue may take a personnel action other than 
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termination for an act prohibited under subsection 
(a). 
(2) DISCRETION.—The exercise of authority 
under paragraph (1) shall be at the sole discretion 
of the Commissioner of Internal Revenue and may 
not be delegated to any other officer. The Commis-
sioner of Internal Revenue, in his sole discretion, 
may establish a procedure which will be used to de-
termine whether an individual should be referred to 
the Commissioner of Internal Revenue for a deter-
mination by the Commissioner under paragraph (1). 
(3) NO
APPEAL.—Any determination of the 
Commissioner of Internal Revenue under this sub-
section may not be appealed in any administrative or 
judicial proceeding. 
(d) TIGTA REPORTING OF TERMINATION OR MITI-
GATION.—Section 7803(d)(1)(E) of the Internal Revenue 
Code of 1986 is amended by inserting ‘‘or section 7 of 
the Small Business Taxpayer Bill of Rights Act of 2013’’ 
after ‘‘1998’’. 
SEC. 
8. 
ALTERNATIVE 
DISPUTE 
RESOLUTION 
PROCE-
DURES. 
(a) IN GENERAL.—Section 7123 of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following new subsection: 
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‘‘(c) AVAILABILITY OF DISPUTE RESOLUTIONS.— 
‘‘(1) IN GENERAL.—The procedures prescribed 
under subsection (b)(1) and the pilot program estab-
lished under subsection (b)(2) shall provide that a 
taxpayer may request mediation or arbitration in 
any case unless the Secretary has specifically ex-
cluded the type of issue involved in such case or the 
class of cases to which such case belongs as not ap-
propriate for resolution under such subsection. The 
Secretary shall make any determination that ex-
cludes a type of issue or a class of cases public with-
in 5 working days and provide an explanation for 
each determination. 
‘‘(2) INDEPENDENT MEDIATORS.— 
‘‘(A) IN GENERAL.—The procedures pre-
scribed under subsection (b)(1) shall provide 
the taxpayer an opportunity to elect to have the 
mediation conducted by an independent, neutral 
individual not employed by the Office of Ap-
peals. 
‘‘(B) COST AND SELECTION.— 
‘‘(i) 
IN
GENERAL.—Any 
taxpayer 
making an election under subparagraph 
(A) shall be required— 
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‘‘(I) to share the costs of such 
independent mediator equally with the 
Office of Appeals, and 
‘‘(II) to limit the selection of the 
mediator to a roster of recognized na-
tional or local neutral mediators. 
‘‘(ii) EXCEPTION.—Clause (i)(I) shall 
not apply to any taxpayer who is an indi-
vidual or who was a small business in the 
preceding calendar year if such taxpayer 
had an adjusted gross income that did not 
exceed 250 percent of the poverty level, as 
determined in accordance with criteria es-
tablished by the Director of the Office of 
Management and Budget, in the taxable 
year preceding the request. 
‘‘(iii) SMALL
BUSINESS.—For pur-
poses of clause (ii), the term ‘small busi-
ness’ has the meaning given such term 
under section 41(b)(3)(D)(iii). 
‘‘(3) AVAILABILITY OF PROCESS.—The proce-
dures prescribed under subsection (b)(1) and the 
pilot program established under subsection (b)(2) 
shall provide the opportunity to elect mediation or 
arbitration at the time when the case is first filed 
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with the Office of Appeals and at any time before 
deliberations in the appeal commence.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect on the date of the enactment 
of this Act. 
SEC. 9. EXTENSION OF TIME FOR CONTESTING IRS LEVY. 
(a) EXTENSION OF TIME FOR RETURN OF PROPERTY 
SUBJECT TO LEVY.—Subsection (b) of section 6343 of the 
Internal Revenue Code of 1986 is amended by striking ‘‘9 
months’’ and inserting ‘‘3 years’’. 
(b) PERIOD OF LIMITATION ON SUITS.—Subsection 
(c) of section 6532 of the Internal Revenue Code of 1986 
is amended— 
(1) in paragraph (1) by striking ‘‘9 months’’ 
and inserting ‘‘3 years’’, and 
(2) in paragraph (2) by striking ‘‘9-month’’ and 
inserting ‘‘3-year’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to— 
(1) levies made after the date of the enactment 
of this Act, and 
(2) levies made on or before such date if the 9- 
month period has not expired under section 6343(b) 
of the Internal Revenue Code of 1986 (without re-
gard to this section) as of such date. 
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SEC. 10. WAIVER OF INSTALLMENT AGREEMENT FEE. 
(a) IN GENERAL.—Section 6159 of the Internal Rev-
enue Code of 1986 is amended by redesignating subsection 
(f) as subsection (g) and by inserting after subsection (e) 
the following new subsection: 
‘‘(f) WAIVER OF INSTALLMENT AGREEMENT FEE.— 
The Secretary shall waive the fees imposed on installment 
agreements under this section for any taxpayer with an 
adjusted gross income that does not exceed 250 percent 
of the poverty level, as determined in accordance with cri-
teria established by the Director of the Office of Manage-
ment and Budget, and who has agreed to make payments 
under the installment agreement by electronic payment 
through a debit instrument.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect on the date of the enactment 
of this Act. 
SEC. 11. SUSPENSION OF RUNNING OF PERIOD FOR FILING 
PETITION OF SPOUSAL RELIEF AND COLLEC-
TION CASES. 
(a) PETITIONS FOR SPOUSAL RELIEF.— 
(1) IN
GENERAL.—Subsection (e) of section 
6015 of the Internal Revenue Code of 1986 is 
amended by adding at the end the following new 
paragraph: 
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‘‘(6) SUSPENSION OF RUNNING OF PERIOD FOR 
FILING PETITION IN TITLE 11 CASES.—In the case 
of a person who is prohibited by reason of a case 
under title 11, United States Code, from filing a pe-
tition under paragraph (1)(A) with respect to a final 
determination of relief under this section, the run-
ning of the period prescribed by such paragraph for 
filing such a petition with respect to such final de-
termination shall be suspended for the period during 
which the person is so prohibited from filing such a 
petition, and for 60 days thereafter.’’. 
(2) EFFECTIVE DATE.—The amendment made 
by this subsection shall apply to petitions filed under 
section 6015(e) of the Internal Revenue Code of 
1986 after the date of the enactment of this Act. 
(b) COLLECTION PROCEEDINGS.— 
(1) IN
GENERAL.—Subsection (d) of section 
6330 of the Internal Revenue Code of 1986 is 
amended— 
(A) by striking ‘‘appeal such determination 
to the Tax Court’’ in paragraph (1) and insert-
ing ‘‘petition the Tax Court for review of such 
determination’’, 
(B) by striking ‘‘JUDICIAL REVIEW OF DE-
TERMINATION’’ in the heading of paragraph (1) 
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and inserting ‘‘PETITION FOR REVIEW BY TAX 
COURT’’, 
(C) by redesignating paragraph (2) as 
paragraph (3), and 
(D) by inserting after paragraph (1) the 
following new paragraph: 
‘‘(2) SUSPENSION OF RUNNING OF PERIOD FOR 
FILING PETITION IN TITLE 11 CASES.—In the case 
of a person who is prohibited by reason of a case 
under title 11, United States Code, from filing a pe-
tition under paragraph (1) with respect to a deter-
mination under this section, the running of the pe-
riod prescribed by such subsection for filing such a 
petition with respect to such determination shall be 
suspended for the period during which the person is 
so prohibited from filing such a petition, and for 30 
days thereafter.’’. 
(2) CONFORMING AMENDMENT.—Subsection (c) 
of section 6320 of such Code is amended by striking 
‘‘(2)(B)’’ and inserting ‘‘(3)(B)’’. 
(3) EFFECTIVE DATE.—The amendments made 
by this subsection shall apply to petitions filed under 
section 6330 of the Internal Revenue Code of 1986 
after the date of the enactment of this Act. 
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SEC. 12. VENUE FOR APPEAL OF SPOUSAL RELIEF AND 
COLLECTION CASES. 
(a) IN GENERAL.—Paragraph (1) of section 7482(b) 
of the Internal Revenue Code of 1986 is amended— 
(1) by striking ‘‘or’’ at the end of subparagraph 
(E), 
(2) by striking the period at the end of sub-
paragraph (F) and inserting a comma, and 
(3) by inserting after subparagraph (F) the fol-
lowing new subparagraphs: 
‘‘(G) in the case of a petition under section 
6015(e), the legal residence of the petitioner, or 
‘‘(H) in the case of a petition under sec-
tion 6320 or 6330— 
‘‘(i) the legal residence of the peti-
tioner if the petitioner is an individual, and 
‘‘(ii) the principal place of business or 
principal office or agency if the petitioner 
is an entity other than an individual.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to petitions filed after the date of 
enactment of this Act. 
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SEC. 13. INCREASE IN MONETARY PENALTIES FOR CER-
TAIN UNAUTHORIZED DISCLOSURES OF IN-
FORMATION. 
(a) IN GENERAL.—Paragraphs (1), (2), (3), and (4) 
of section 7213(a) of the Internal Revenue Code of 1986 
are each amended by striking ‘‘$5,000’’ and inserting 
‘‘$10,000’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to disclosures made after the date 
of the enactment of this Act. 
SEC. 14. DE NOVO TAX COURT REVIEW OF CLAIMS FOR EQ-
UITABLE INNOCENT SPOUSE RELIEF. 
(a) IN GENERAL.—Subparagraph (A) of section 
6015(e)(1) of the Internal Revenue Code of 1986 is 
amended by adding at the end the following new flush sen-
tence: 
‘‘Any review of a determination by the Sec-
retary with respect to a claim for equitable re-
lief under subsection (f) shall be reviewed de 
novo by the Tax Court.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to petitions filed or pending before 
the Tax Court on and after the date of the enactment of 
this Act. 
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SEC. 15. BAN ON RAISING NEW ISSUES ON APPEAL. 
(a) IN GENERAL.—Chapter 77 of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following new section: 
‘‘SEC. 7529. PROHIBITION ON INTERNAL REVENUE SERVICE 
RAISING NEW ISSUES IN AN INTERNAL AP-
PEAL. 
‘‘(a) IN GENERAL.—In reviewing an appeal of any 
determination initially made by the Internal Revenue 
Service, the Internal Revenue Service Office of Appeals 
may not consider or decide any issue that is not within 
the scope of the initial determination. 
‘‘(b) CERTAIN ISSUES DEEMED OUTSIDE OF SCOPE 
OF DETERMINATION.—For purposes of subsection (a), the 
following matters shall be considered to be not within the 
scope of a determination: 
‘‘(1) Any issue that was not raised in a notice 
of deficiency or an examiner’s report which is the 
subject of the appeal. 
‘‘(2) Any deficiency in tax which was not in-
cluded in the initial determination. 
‘‘(3) Any theory or justification for a tax defi-
ciency which was not considered in the initial deter-
mination. 
‘‘(c) NO INFERENCE WITH RESPECT
TO ISSUES 
RAISED BY TAXPAYERS.—Nothing in this section shall be 
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construed to provide any limitation in addition to any limi-
tations in effect on the date of the enactment of this sec-
tion on the right of a taxpayer to raise an issue, theory, 
or justification on an appeal from a determination initially 
made by the Internal Revenue Service that was not within 
the scope of the initial determination.’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for chapter 77 of such Code is amended by adding at the 
end the following new item: 
‘‘Sec. 7529. Prohibition on Internal Revenue Service raising new issues in an 
internal appeal.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to matters filed or pending with 
the Internal Revenue Service Office of Appeals on or after 
the date of the enactment of this Act. 
Æ 
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