II 
116TH CONGRESS 
1ST SESSION H. R. 3151 
IN THE SENATE OF THE UNITED STATES 
JUNE 11, 2019 
Received 
AN ACT 
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, 
VerDate Sep 11 2014 
21:55 Jun 13, 2019
Jkt 089200
PO 00000
Frm 00001
Fmt 6652
Sfmt 6201
E:\BILLS\H3151.RDS
H3151
kjohnson on DSK79L0C42 with BILLS
HR 3151 RDS
SECTION 1. SHORT TITLE; ETC. 
(a) SHORT TITLE.—This Act may be cited as the 
‘‘Taxpayer First Act’’. 
(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 
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. 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. 
VerDate Sep 11 2014 
21:55 Jun 13, 2019
Jkt 089200
PO 00000
Frm 00002
Fmt 6652
Sfmt 6211
E:\BILLS\H3151.RDS
H3151
kjohnson on DSK79L0C42 with BILLS
HR 3151 RDS
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 
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. Identity protection personal identification numbers. 
Sec. 2006. Single point of contact for tax-related identity theft victims. 
Sec. 2007. Notification of suspected identity theft. 
Sec. 2008. Guidelines for stolen identity refund fraud cases. 
Sec. 2009. 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. Internet platform for Form 1099 filings. 
Sec. 2103. 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. 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 
VerDate Sep 11 2014 
21:55 Jun 13, 2019
Jkt 089200
PO 00000
Frm 00003
Fmt 6652
Sfmt 6211
E:\BILLS\H3151.RDS
H3151
kjohnson on DSK79L0C42 with BILLS
HR 3151 RDS
Sec. 3001. Prohibition on rehiring any employee of the Internal Revenue Serv-
ice who was involuntarily separated from service for mis-
conduct. 
Sec. 3002. Notification of unauthorized inspection or disclosure of returns and 
return information. 
Subtitle B—Provisions Relating to Exempt Organizations 
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—Revenue Provision 
Sec. 3201. Increase in penalty for failure to file. 
TITLE IV—BUDGETARY EFFECTS 
Sec. 4001. Determination of budgetary effects. 
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-
VerDate Sep 11 2014 
21:55 Jun 13, 2019
Jkt 089200
PO 00000
Frm 00004
Fmt 6652
Sfmt 6201
E:\BILLS\H3151.RDS
H3151
kjohnson on DSK79L0C42 with BILLS
HR 3151 RDS
cial to be known as the ‘Chief of Appeals’. The 
Chief of Appeals shall report directly to the 
Commissioner of Internal Revenue and shall be 
entitled to compensation at the same rate as 
the highest rate of basic pay established for the 
Senior Executive Service under section 5382 of 
title 5, United States Code. 
‘‘(B) APPOINTMENT.—The Chief of Ap-
peals shall be appointed by the Commissioner of 
Internal Revenue without regard to the provi-
sions of title 5, United States Code, relating to 
appointments in the competitive service or the 
Senior Executive Service. 
‘‘(C) QUALIFICATIONS.—An individual ap-
pointed under subparagraph (B) shall have ex-
perience and expertise in— 
‘‘(i) administration of, and compliance 
with, Federal tax laws, 
‘‘(ii) a broad range of compliance 
cases, and 
‘‘(iii) management of large service or-
ganizations. 
‘‘(3) PURPOSES AND DUTIES OF OFFICE.—It 
shall be the function of the Internal Revenue Service 
VerDate Sep 11 2014 
21:55 Jun 13, 2019
Jkt 089200
PO 00000
Frm 00005
Fmt 6652
Sfmt 6201
E:\BILLS\H3151.RDS
H3151
kjohnson on DSK79L0C42 with BILLS
HR 3151 RDS
Independent Office of Appeals to resolve Federal tax 
controversies without litigation on a basis which— 
‘‘(A) is fair and impartial to both the Gov-
ernment and the taxpayer, 
‘‘(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 Internal Revenue shall provide 
such taxpayer a written notice which— 
‘‘(i) provides a detailed description of 
the facts involved, the basis for the deci-
VerDate Sep 11 2014 
21:55 Jun 13, 2019
Jkt 089200
PO 00000
Frm 00006
Fmt 6652
Sfmt 6201
E:\BILLS\H3151.RDS
H3151
kjohnson on DSK79L0C42 with BILLS
HR 3151 RDS
sion to deny the request, and a detailed ex-
planation of how the basis of such decision 
applies to such facts, and 
‘‘(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 Internal Revenue shall submit a 
written report to Congress on an annual basis 
which includes the number of requests described 
in subparagraph (A) which were denied and the 
reasons (described by category) that such re-
quests were denied. 
‘‘(C) PROCEDURES FOR PROTESTING DE-
NIAL OF REQUEST.—The Commissioner of In-
ternal Revenue shall prescribe procedures for 
protesting to the Commissioner of Internal Rev-
enue a denial of a request described in subpara-
graph (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 
VerDate Sep 11 2014 
21:55 Jun 13, 2019
Jkt 089200
PO 00000
Frm 00007
Fmt 6652
Sfmt 6201
E:\BILLS\H3151.RDS
H3151
kjohnson on DSK79L0C42 with BILLS