‘‘(B) shall not result in a suspension of the 
running of such period of limitations after any 
date on which a lapse of a deadline, a court fil-
ing, or a court order establishes that the tax-
payer has forfeited or otherwise lost the right to 
pursue such dispute.’’. 
(c) CROSS REFERENCE.—Section 6511(i) of such Code 
is amended by adding at the end the following new para-
graph: 
‘‘(8) For limitations in case of collection ac-
tion proceedings, see section 6330(e).’’. 
(d) EFFECTIVE DATE.—The amendments made by this 
section shall apply to the running of any period of limita-
tions if such period (determined without regard to the 
amendments made by this section) ends on or after the date 
of the enactment of this Act. 
SEC. 3. PROHIBITION ON CREDITING OF OVERPAYMENTS 
AGAINST DISPUTED TAX LIABILITY DURING 
COLLECTION ACTION PROCEEDINGS. 
(a) IN GENERAL.—Section 6402 of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following new subsection: 
‘‘(o) PROHIBITION ON CREDITING OF OVERPAYMENTS 
AGAINST DISPUTED TAX LIABILITY DURING COLLECTION 
ACTION PROCEEDINGS.—If a hearing is properly requested 
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under section 6320(a)(3)(B) or 6330(a)(3)(B), and an un-
derlying tax liability referred to in section 6330(c)(2)(B) 
is properly disputed at such hearing, such tax liability shall 
not, except with the consent of the taxpayer, be taken into 
account under subsection (a) for the period during which 
the period of limitations for filing a claim for credit or re-
fund relating to such tax liability is suspended by reason 
of section 6330(e).’’. 
(b) CLARIFICATION OF APPLICATION OF CERTAIN LEVY 
HEARING
RULES
TO
LIEN
HEARINGS.—Section 
6330(c)(2)(A) of such Code is amended by striking ‘‘unpaid 
tax or the proposed levy’’ and inserting ‘‘unpaid tax, collec-
tion action, or proposed collection action’’. 
(c) EFFECTIVE DATES.— 
(1) IN GENERAL.—The amendment made by sub-
section (a) shall apply with respect to any period de-
scribed in section 6402(o) of the Internal Revenue 
Code of 1986 (as added by this section) if any portion 
of such period is after the date of the enactment of 
this Act. 
(2) CLARIFICATION OF APPLICATION OF CERTAIN 
LEVY
HEARING
RULES
TO
LIEN
HEARINGS.—The 
amendment made by subsection (b) shall take effect on 
the date of the enactment of this Act. 
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SEC. 4. EXPANSION OF JURISDICTION OF TAX COURT. 
(a) IN GENERAL.—Section 6330(d)(1) of the Internal 
Revenue Code of 1986 is amended to read as follows: 
‘‘(1) PETITION FOR REVIEW BY TAX COURT.— 
‘‘(A) IN GENERAL.—In the case of a deter-
mination under this section, the person may, 
within 30 days of such determination, petition 
the Tax Court for review of— 
‘‘(i) such determination, and 
‘‘(ii) any underlying tax liability re-
ferred to in subsection (c)(2)(B) which is 
properly disputed at the hearing in which 
such determination is made. 
‘‘(B) JURISDICTION OF TAX COURT.—Upon 
the filing of a petition, the Tax Court shall have 
jurisdiction with respect to— 
‘‘(i) the determination referred to in 
subparagraph (A)(i), 
‘‘(ii) any underlying tax liability re-
ferred to in subparagraph (A)(ii), and 
‘‘(iii) any equitable tolling of the 30- 
day deadline referred to in subparagraph 
(A). 
‘‘(C) RETENTION OF JURISDICTION.—Upon 
a determination being made under this section, 
subparagraphs (A) and (B) shall apply whether 
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or not the Secretary abandons the collection ac-
tion or proposed collection action at issue in 
such determination.’’. 
(b) EFFECTIVE DATE.—The amendment made by this 
section shall apply with respect to petitions filed after the 
date of the enactment of this Act. 
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Union Calendar No. 373 
119TH CONGRESS 
2D SESSION 
H. R. 6506 
[Report No. 119–428] 
A BILL 
To amend the Internal Revenue Code of 1986 to 
suspend the period of limitations on filing a 
claim for credit or refund during collection action 
proceedings, to prohibit the crediting of overpay-
ments against disputed tax liability during such 
proceedings, and to expand the jurisdiction of the 
Tax Court. 
JANUARY 7, 2026 
Reported with an amendment, committed to the Com-
mittee of the Whole House on the State of the Union, 
and ordered to be printed 
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