I 
115TH CONGRESS 
1ST SESSION H. R. 3340 
To amend the Internal Revenue Code of 1986 to provide taxpayer protection 
and assistance, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
JULY 20, 2017 
Mr. DOGGETT (for himself, Ms. JUDY CHU of California, Ms. DELBENE, Mr. 
HIGGINS of New York, Mr. LEVIN, Ms. SEWELL of Alabama, and Mr. 
THOMPSON of California) introduced the following bill; which was re-
ferred to the Committee on Ways and Means, and in addition to the 
Committee on Financial Services, for a period to be subsequently deter-
mined by the Speaker, in each case for consideration of such provisions 
as fall within the jurisdiction of the committee concerned 
A BILL 
To amend the Internal Revenue Code of 1986 to provide 
taxpayer protection and assistance, 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 
‘‘Strengthening Taxpayer Rights Act of 2017’’. 
(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 
VerDate Sep 11 2014 
01:47 Aug 01, 2017
Jkt 069200
PO 00000
Frm 00001
Fmt 6652
Sfmt 6201
E:\BILLS\H3340.IH
H3340
lotter on DSKBCFDHB2PROD with BILLS
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, as amended. 
(c) TABLE OF CONTENTS.—The table of contents of 
this Act is as follows: 
Sec. 1. Short title; etc. 
TITLE I—PREPARATION OF TAX RETURNS 
Sec. 101. Preparer penalties with respect to preparation of returns and other 
submissions. 
Sec. 102. Limit redisclosures and uses of consent-based disclosures of tax re-
turn information. 
TITLE II—IMPROVING IRS PROCEDURES 
Sec. 201. Modification of requirements relating to tax lien information con-
tained in consumer credit reports. 
Sec. 202. De novo tax court review of innocent spouse relief determinations. 
Sec. 203. Removal of nonpayment period from list of triggering events for re-
turns relating to cancellation of indebtedness. 
Sec. 204. Special rules for levies that attach to a fixed and determinable right. 
TITLE I—PREPARATION OF TAX 
RETURNS 
SEC. 101. PREPARER PENALTIES WITH RESPECT TO PREPA-
RATION OF RETURNS AND OTHER SUBMIS-
SIONS. 
(a) INCLUSION OF OTHER SUBMISSIONS IN PENALTY 
PROVISIONS.— 
(1) UNDERSTATEMENT OF TAXPAYER’S LIABIL-
ITY BY TAX RETURN PREPARER.— 
(A) IN GENERAL.—Section 6694 is amend-
ed by striking ‘‘return or claim of refund’’ each 
place it appears and inserting ‘‘return, claim of 
refund, or other submission to the Secretary’’. 
VerDate Sep 11 2014 
01:47 Aug 01, 2017
Jkt 069200
PO 00000
Frm 00002
Fmt 6652
Sfmt 6201
E:\BILLS\H3340.IH
H3340
lotter on DSKBCFDHB2PROD with BILLS
(B) CONFORMING AMENDMENTS.—Section 
6694, as amended by paragraph (1), is amend-
ed by striking ‘‘return or claim’’ each place it 
appears and inserting ‘‘return, claim, or other 
submission to the Secretary’’. 
(2) INCREASE IN PENALTY IN CASE OF GROSS 
MISCONDUCT.—Subsection (b) of section 6694 is 
amended by adding at the end the following new 
paragraph: 
‘‘(4) INCREASE IN PENALTY IN CASE OF GROSS 
MISCONDUCT.—In the case of an understatement to 
which this section applies that is attributable to the 
tax return preparer’s making a false or fraudulent 
return or claim for refund without the taxpayer’s 
knowledge, subsection (a) shall be applied by sub-
stituting ‘100 percent of the amount of the under-
statement’ for ‘50 percent of the amount derived (or 
to be derived) by the tax return preparer with re-
spect to the return or claim’. This penalty shall be 
in addition to any other penalties provided by law.’’. 
(3) OTHER ASSESSABLE PENALTIES.— 
(A) IN GENERAL.—Section 6695 is amend-
ed by striking ‘‘return or claim for refund’’ 
each place it appears and inserting ‘‘return, 
claim for refund, or other submission’’. 
VerDate Sep 11 2014 
01:47 Aug 01, 2017
Jkt 069200
PO 00000
Frm 00003
Fmt 6652
Sfmt 6201
E:\BILLS\H3340.IH
H3340
lotter on DSKBCFDHB2PROD with BILLS
(B) CONFORMING AMENDMENTS.—Section 
6695, as amended by paragraph (1), is amend-
ed by striking ‘‘return or claim’’ each place it 
appears and inserting ‘‘return, claim, or other 
submission’’. 
(b) INCREASE IN CERTAIN OTHER ASSESSABLE PEN-
ALTY AMOUNTS.— 
(1) IN GENERAL.—Subsections (a), (b), and (c) 
of section 6695 are each amended by striking ‘‘$50’’ 
and inserting ‘‘$1,000’’. 
(2) REMOVAL OF ANNUAL LIMITATION.—Sub-
sections (a), (b), and (c) of section 6695 are each 
amended by striking the last sentence thereof. 
(c) REVIEW BY THE TREASURY INSPECTOR GEN-
ERAL FOR TAX ADMINISTRATION.—Subparagraph (A) of 
section 7803(d)(2) is amended by striking ‘‘and’’ at the 
end of clause (iii), by striking the period at the end of 
clause (iv) and inserting ‘‘, and’’, and by adding at the 
end the following new clause: 
‘‘(v) a summary of the penalties as-
sessed and collected during the reporting 
period under sections 6694 and 6695 and 
under the regulations promulgated under 
section 330 of title 31, United States 
Code, and a review of the procedures by 
VerDate Sep 11 2014 
01:47 Aug 01, 2017
Jkt 069200
PO 00000
Frm 00004
Fmt 6652
Sfmt 6201
E:\BILLS\H3340.IH
H3340
lotter on DSKBCFDHB2PROD with BILLS
which violations are identified and pen-
alties are assessed under those sections,’’. 
(d) ADDITIONAL CERTIFICATION
ON DOCUMENTS 
OTHER THAN RETURNS.— 
(1) IDENTIFYING NUMBER REQUIRED FOR ALL 
SUBMISSIONS
TO
THE
IRS
BY
TAX
RETURN
PRE-
PARERS.—The first sentence of paragraph (4) of 
section 6109(a) is amended by striking ‘‘return or 
claim for refund’’ and inserting ‘‘return, claim for 
refund, statement, or other document’’. 
(2) EFFECTIVE DATE.—The amendment made 
by paragraph (1) shall apply to any return, claim for 
refund, or submission to the Secretary that is filed 
after the date of the enactment of this Act. 
(e) COORDINATION WITH SECTION 6060(a).—The 
Secretary of the Treasury shall coordinate the require-
ments under the regulations promulgated under sections 
330 and 330A of title 31, United States Code, with the 
return requirements of section 6060 of the Internal Rev-
enue Code of 1986. 
(f) EFFECTIVE DATE.—The regulations required by 
this section shall be prescribed not later than one year 
after the date of the enactment of this Act. 
VerDate Sep 11 2014 
01:47 Aug 01, 2017
Jkt 069200
PO 00000
Frm 00005
Fmt 6652
Sfmt 6201
E:\BILLS\H3340.IH
H3340
lotter on DSKBCFDHB2PROD with BILLS
SEC. 102. LIMIT REDISCLOSURES AND USES OF CONSENT- 
BASED DISCLOSURES OF TAX RETURN INFOR-
MATION. 
(a) IN GENERAL.—Subsection (c) of section 6103 is 
amended by striking ‘‘However, return’’ and inserting the 
following: ‘‘Persons designated by the taxpayer to receive 
return information shall not use the information for any 
purpose other than the express purpose for which consent 
was granted and shall not disclose return information to 
any other person without the express permission of, or re-
quest by, the taxpayer. Return’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to disclosures after the date of the 
enactment of this Act. 
TITLE II—IMPROVING IRS 
PROCEDURES 
SEC. 201. MODIFICATION OF REQUIREMENTS RELATING TO 
TAX LIEN INFORMATION CONTAINED IN CON-
SUMER CREDIT REPORTS. 
(a) IN GENERAL.—Paragraph (3) of section 605(a) 
of the Fair Credit Reporting Act (15 U.S.C. 1681c(a)(3)) 
is amended to read as follows: 
‘‘(3) TAX LIENS.—The following tax liens: 
‘‘(A) Any tax lien released pursuant to sec-
tion 6325(a) of the Internal Revenue Code of 
VerDate Sep 11 2014 
01:47 Aug 01, 2017
Jkt 069200
PO 00000
Frm 00006
Fmt 6652
Sfmt 6201
E:\BILLS\H3340.IH
H3340
lotter on DSKBCFDHB2PROD with BILLS
1986 not more than 2 years after the date that 
the notice of such lien was filed. 
‘‘(B) Any tax lien released pursuant to sec-
tion 6325(a) of such Code— 
‘‘(i) more than 2 years after the date 
that the notice of such lien was filed, and 
‘‘(ii) more than 2 years before the re-
port. 
‘‘(C) Any tax lien if— 
‘‘(i) the notice of such lien was not 
refiled during the required refiling period 
(as defined in section 6323(g)(3) of such 
Code), and 
‘‘(ii) such period ends more than 6 
years before the report. 
‘‘(D) Any tax lien the notice of which is 
withdrawn pursuant to section 6323(j)(1) of 
such Code. 
‘‘(E) Any tax lien released pursuant to sec-
tion 6326(b) of such Code if the notice of such 
lien was erroneously filed.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect on the date of the enactment 
of this Act. 
VerDate Sep 11 2014 
01:47 Aug 01, 2017
Jkt 069200
PO 00000
Frm 00007
Fmt 6652
Sfmt 6201
E:\BILLS\H3340.IH
H3340
lotter on DSKBCFDHB2PROD with BILLS
SEC. 202. DE NOVO TAX COURT REVIEW OF INNOCENT 
SPOUSE RELIEF DETERMINATIONS. 
(a) IN GENERAL.—Section 6015 is amended— 
(1) in subsection (e), by adding at the end the 
following new paragraph: 
‘‘(6) 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 
‘‘(B) relief is not available to such indi-
vidual under subsection (b) or (c), 
the Secretary may relieve such individual of such li-
ability. 
VerDate Sep 11 2014 
01:47 Aug 01, 2017
Jkt 069200
PO 00000
Frm 00008
Fmt 6652
Sfmt 6201
E:\BILLS\H3340.IH
H3340
lotter on DSKBCFDHB2PROD with BILLS
‘‘(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 and after the date of the enactment of this 
Act. 
SEC. 203. REMOVAL OF NONPAYMENT PERIOD FROM LIST 
OF TRIGGERING EVENTS FOR RETURNS RE-
LATING TO CANCELLATION OF INDEBTED-
NESS. 
(a) IN GENERAL.—Subsection (c) of section 6050P 
is amended by adding at the end the following new para-
graph: 
‘‘(4) DETERMINING
DATE
OF
DISCHARGE.— 
Whether an entity has discharged the indebtedness 
of any person shall not be determined based solely 
VerDate Sep 11 2014 
01:47 Aug 01, 2017
Jkt 069200
PO 00000
Frm 00009
Fmt 6652
Sfmt 6201
E:\BILLS\H3340.IH
H3340
lotter on DSKBCFDHB2PROD with BILLS
on the passage of a specified period of time during 
which the entity has not received payment on such 
indebtedness.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to discharges of indebtedness after 
the date of the enactment of this Act. 
SEC. 204. SPECIAL RULES FOR LEVIES THAT ATTACH TO A 
FIXED AND DETERMINABLE RIGHT. 
(a) IN GENERAL.—Section 6331 is amended by re-
designating subsection (l) as subsection (m) and by insert-
ing after subsection (k) the following new subsection: 
‘‘(l) LIMITATION ON LEVY AFTER EXPIRATION OF 
COLLECTION PERIOD.— 
‘‘(1) PENALTIES AND INTEREST.—In the case 
of a levy that attaches to a fixed and determinable 
right to payments or other property, penalties, addi-
tions to tax, and interest shall not accrue after the 
expiration of the period of limitations provided in 
section 6502. 
‘‘(2) 
RETIREMENT
AND
DISABILITY
PAY-
MENTS.—In the case of a levy on benefits under title 
II of the Social Security Act, benefits under a plan 
on account of a disability, or retirement benefits or 
amounts held in a retirement plan, such levy is not 
enforceable with respect to such benefits or amounts 
VerDate Sep 11 2014 
01:47 Aug 01, 2017
Jkt 069200
PO 00000
Frm 00010
Fmt 6652
Sfmt 6201
E:\BILLS\H3340.IH
H3340
lotter on DSKBCFDHB2PROD with BILLS
after the expiration of the period of limitations pro-
vided in section 6502 unless the taxpayer has com-
mitted a flagrant act (as defined in section 
6334(f)(2)).’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to levies served after the date of 
the enactment of this Act. 
Æ 
VerDate Sep 11 2014 
01:47 Aug 01, 2017
Jkt 069200
PO 00000
Frm 00011
Fmt 6652
Sfmt 6301
E:\BILLS\H3340.IH
H3340
lotter on DSKBCFDHB2PROD with BILLS