I 
115TH CONGRESS 
2D SESSION 
H. R. 7227 
To amend the Internal Revenue Code of 1986 to modernize and improve 
the Internal Revenue Service, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
DECEMBER 10, 2018 
Ms. JENKINS of Kansas (for herself and Mr. LEWIS of Georgia) introduced 
the following bill; which was referred to the Committee on Ways and 
Means, and in addition to the Committee on Financial Services, for a pe-
riod to be subsequently determined by the Speaker, in each case for con-
sideration of such provisions as fall within the jurisdiction of the com-
mittee concerned 
A BILL 
To amend the Internal Revenue Code of 1986 to modernize 
and improve the Internal Revenue Service, and for other 
purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE; ETC. 
(a) SHORT TITLE.—This Act may be cited as the 
‘‘Taxpayer First Act of 2018’’. 
(b) AMENDMENT OF 1986 CODE.—Except as other-
wise expressly provided, whenever in this Act an amend-
ment or repeal is expressed in terms of an amendment 
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to, or repeal of, a section or other provision, the reference 
shall be considered to be made to a section or other provi-
sion of the Internal Revenue Code of 1986. 
(c) TABLE OF CONTENTS.—The table of contents for 
this Act is as follows: 
Sec. 1. Short title; etc. 
TITLE I—PUTTING TAXPAYERS FIRST 
Subtitle A—Independent Appeals Process 
Sec. 1001. Establishment of Internal Revenue Service Independent Office of 
Appeals. 
Subtitle B—Improved Service 
Sec. 1101. Comprehensive customer service strategy. 
Sec. 1102. IRS Free File Program. 
Sec. 1103. Low-income exception for payments otherwise required in connection 
with a submission of an offer-in-compromise. 
Subtitle C—Sensible Enforcement 
Sec. 1201. Internal Revenue Service seizure requirements with respect to struc-
turing transactions. 
Sec. 1202. Exclusion of interest received in action to recover property seized by 
the Internal Revenue Service based on structuring transaction. 
Sec. 1203. Clarification of equitable relief from joint liability. 
Sec. 1204. Modification of procedures for issuance of third-party summons. 
Sec. 1205. Private debt collection and special compliance personnel program. 
Sec. 1206. Reform of notice of contact of third parties. 
Sec. 1207. Modification of authority to issue designated summons. 
Sec. 1208. Limitation on access of non-Internal Revenue Service employees to 
returns and return information. 
Subtitle D—Organizational Modernization 
Sec. 1301. Office of the National Taxpayer Advocate. 
Sec. 1302. Modernization of Internal Revenue Service organizational structure. 
Subtitle E—Other Provisions 
Sec. 1401. Return preparation programs for applicable taxpayers. 
Sec. 1402. Provision of information regarding low-income taxpayer clinics. 
Sec. 1403. Notice from IRS regarding closure of taxpayer assistance centers. 
Sec. 1404. Rules for seizure and sale of perishable goods restricted to only per-
ishable goods. 
Sec. 1405. Whistleblower reforms. 
Sec. 1406. Customer service information. 
Sec. 1407. Misdirected tax refund deposits. 
TITLE II—21ST CENTURY IRS 
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Subtitle A—Cybersecurity and Identity Protection 
Sec. 2001. Public-private partnership to address identity theft refund fraud. 
Sec. 2002. Recommendations of Electronic Tax Administration Advisory Com-
mittee regarding identity theft refund fraud. 
Sec. 2003. Information sharing and analysis center. 
Sec. 2004. Compliance by contractors with confidentiality safeguards. 
Sec. 2005. Report on electronic payments. 
Sec. 2006. Identity protection personal identification numbers. 
Sec. 2007. Single point of contact for tax-related identity theft victims. 
Sec. 2008. Notification of suspected identity theft. 
Sec. 2009. Guidelines for stolen identity refund fraud cases. 
Sec. 2010. Increased penalty for improper disclosure or use of information by 
preparers of returns. 
Subtitle B—Development of Information Technology 
Sec. 2101. Management of Internal Revenue Service information technology. 
Sec. 2102. Development of online accounts and portals. 
Sec. 2103. Internet platform for Form 1099 filings. 
Sec. 2104. Streamlined critical pay authority for information technology posi-
tions. 
Subtitle C—Modernization of Consent-Based Income Verification System 
Sec. 2201. Disclosure 
of 
taxpayer 
information 
for 
third-party 
income 
verification. 
Sec. 2202. Limit redisclosures and uses of consent-based disclosures of tax re-
turn information. 
Subtitle D—Expanded Use of Electronic Systems 
Sec. 2301. Electronic filing of returns. 
Sec. 2302. Uniform standards for the use of electronic signatures for disclosure 
authorizations to, and other authorizations of, practitioners. 
Sec. 2303. Payment of taxes by debit and credit cards. 
Sec. 2304. Requirement that electronically prepared paper returns include scan-
nable code. 
Sec. 2305. Authentication of users of electronic services accounts. 
Subtitle E—Other Provisions 
Sec. 2401. Repeal of provision regarding certain tax compliance procedures and 
reports. 
Sec. 2402. Comprehensive training strategy. 
TITLE III—MISCELLANEOUS PROVISIONS 
Subtitle A—Reform of Laws Governing Internal Revenue Service Employees 
Sec. 3001. Electronic record retention. 
Sec. 3002. Prohibition on rehiring any employee of the Internal Revenue Serv-
ice who was involuntarily separated from service for mis-
conduct. 
Sec. 3003. Notification of unauthorized inspection or disclosure of returns and 
return information. 
Subtitle B—Provisions Relating to Exempt Organizations 
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Sec. 3101. Mandatory e-filing by exempt organizations. 
Sec. 3102. Notice required before revocation of tax exempt status for failure to 
file return. 
Subtitle C—Tax Court 
Sec. 3301. Disqualification of judge or magistrate judge of the Tax Court. 
Sec. 3302. Opinions and judgments. 
Sec. 3303. Title of special trial judge changed to magistrate judge of the Tax 
Court. 
Sec. 3304. Repeal of deadwood related to Board of Tax Appeals. 
TITLE I—PUTTING TAXPAYERS 
FIRST 
Subtitle A—Independent Appeals 
Process 
SEC. 1001. ESTABLISHMENT OF INTERNAL REVENUE SERV-
ICE INDEPENDENT OFFICE OF APPEALS. 
(a) IN GENERAL.—Section 7803 is amended by add-
ing at the end the following new subsection: 
‘‘(e) INDEPENDENT OFFICE OF APPEALS.— 
‘‘(1) ESTABLISHMENT.—There is established in 
the Internal Revenue Service an office to be known 
as the ‘Internal Revenue Service Independent Office 
of Appeals’. 
‘‘(2) CHIEF OF APPEALS.— 
‘‘(A) IN GENERAL.—The Internal Revenue 
Service Independent Office of Appeals shall be 
under the supervision and direction of an offi-
cial to be known as the ‘Chief of Appeals’. The 
Chief of Appeals shall report directly to the 
Commissioner of the Internal Revenue Service 
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‘‘(B) promotes a consistent application and 
interpretation of, and voluntary compliance 
with, the Federal tax laws, and 
‘‘(C) enhances public confidence in the in-
tegrity and efficiency of the Internal Revenue 
Service. 
‘‘(4) RIGHT OF APPEAL.—The resolution proc-
ess described in paragraph (3) shall be generally 
available to all taxpayers. 
‘‘(5) LIMITATION ON DESIGNATION OF CASES 
AS NOT ELIGIBLE FOR REFERRAL TO INDEPENDENT 
OFFICE OF APPEALS.— 
‘‘(A) IN GENERAL.—If any taxpayer which 
is in receipt of a notice of deficiency authorized 
under section 6212 requests referral to the In-
ternal Revenue Service Independent Office of 
Appeals and such request is denied, the Com-
missioner of the Internal Revenue Service shall 
provide such taxpayer a written notice which— 
‘‘(i) provides a detailed description of 
the facts involved, the basis for the deci-
sion to deny the request, and a detailed ex-
planation of how the basis of such decision 
applies to such facts, and 
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‘‘(ii) describes the procedures pre-
scribed under subparagraph (C) for pro-
testing the decision to deny the request. 
‘‘(B) REPORT TO CONGRESS.—The Com-
missioner of the Internal Revenue Service shall 
submit a written report to Congress on an an-
nual basis which includes the number of re-
quests described in subparagraph (A) which 
were denied and the reasons (described by cat-
egory) that such requests were denied. 
‘‘(C) PROCEDURES FOR PROTESTING DE-
NIAL OF REQUEST.—The Commissioner of the 
Internal Revenue Service shall prescribe proce-
dures for protesting to the Commissioner of the 
Internal Revenue Service a denial of a request 
described in subparagraph (A). 
‘‘(D) NOT APPLICABLE TO FRIVOLOUS PO-
SITIONS.—This paragraph shall not apply to a 
request for referral to the Internal Revenue 
Service Independent Office of Appeals which is 
denied on the basis that the issue involved is a 
frivolous position (within the meaning of section 
6702(c)). 
‘‘(6) STAFF.— 
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‘‘(A) IN GENERAL.—All personnel in the 
Internal Revenue Service Independent Office of 
Appeals shall report to the Chief of Appeals. 
‘‘(B) ACCESS
TO
STAFF
OF
OFFICE
OF 
THE CHIEF COUNSEL.—The Chief of Appeals 
shall have authority to obtain legal assistance 
and advice from the staff of the Office of the 
Chief Counsel. The Chief Counsel shall ensure 
that such assistance and advice is provided by 
staff of the Office of the Chief Counsel who 
were not involved in the case with respect to 
which such assistance and advice is sought and 
who are not involved in preparing such case for 
litigation. 
‘‘(7) ACCESS TO CASE FILES.— 
‘‘(A) IN GENERAL.—In any case in which 
a conference with the Internal Revenue Service 
Independent Office of Appeals has been sched-
uled upon request of a specified taxpayer, the 
Chief of Appeals shall ensure that such tax-
payer is provided access to the nonprivileged 
portions of the case file on record regarding the 
disputed issues (other than documents provided 
by the taxpayer to the Internal Revenue Serv-
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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 $5,000,000 for 
the taxable year to which the dispute 
relates. 
‘‘(ii) 
AGGREGATION
RULE.—Rules 
similar to the rules of section 448(c)(2) 
shall apply for purposes of clause (i)(II).’’. 
(b) CONFORMING AMENDMENTS.— 
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(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’’. 
(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-
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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. 
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 shall submit to Congress a writ-
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ten comprehensive customer service strategy for the Inter-
nal 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); 
(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. 
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(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. IRS FREE FILE PROGRAM. 
(a) IN GENERAL.— 
(1) The Secretary of the Treasury, or the Sec-
retary’s delegate, shall continue to operate the IRS 
Free File Program as established by the Internal 
Revenue Service and published in the Federal Reg-
ister on November 4, 2002 (67 Fed. Reg. 67247), 
including any subsequent agreements and governing 
rules established pursuant thereto. 
(2) The IRS Free File Program shall continue 
to provide free commercial-type online individual in-
come tax preparation and electronic filing services to 
the lowest 70 percent of taxpayers by adjusted gross 
income. The number of taxpayers eligible to receive 
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such services each year shall be calculated by the In-
ternal Revenue Service annually based on prior year 
aggregate taxpayer adjusted gross income data. 
(3) In addition to the services described in 
paragraph (2), and in the same manner, the IRS 
Free File Program shall continue to make available 
to all taxpayers (without regard to income) a basic, 
online electronic fillable forms utility. 
(4) The IRS Free File Program shall continue 
to work cooperatively with the private sector to pro-
vide the free individual income tax preparation and 
the electronic filing services described in paragraphs 
(2) and (3). 
(5) The IRS Free File Program shall work co-
operatively with State government agencies to en-
hance and expand the use of the program to provide 
needed benefits to the taxpayer while reducing the 
cost of processing returns. 
(b) INNOVATIONS.—The Secretary of the Treasury, 
or the Secretary’s delegate, shall work with the private 
sector through the IRS Free File Program to identify and 
implement, consistent with applicable law, innovative new 
program features to improve and simplify the taxpayer’s 
experience with completing and filing individual income 
tax returns through voluntary compliance. 
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SEC. 1103. 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 
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: 
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‘‘(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.— 
‘‘(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 
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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 
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 
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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 
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.’’. 
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(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.’’. 
(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.— 
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‘‘(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 
‘‘(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. 
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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-
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 
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 
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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 
‘‘(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— 
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