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term by section 11101 of title 40, United States 
Code. 
‘‘(B) INTERNAL REVENUE SERVICE.—Any 
reference in this subsection to the Internal Rev-
enue Service includes a reference to all compo-
nents of the Internal Revenue Service, includ-
ing— 
‘‘(i) the Office of the Taxpayer Advo-
cate, 
‘‘(ii) the Criminal Investigation Divi-
sion of the Internal Revenue Service, and 
‘‘(iii) except as otherwise provided by 
the Secretary with respect to information 
technology related to matters described in 
subsection (b)(3)(B), the Office of the 
Chief Counsel.’’. 
(b) INDEPENDENT VERIFICATION AND VALIDATION 
OF THE CUSTOMER ACCOUNT DATA ENGINE 2 AND EN-
TERPRISE CASE MANAGEMENT SYSTEM.— 
(1) IN GENERAL.—The Commissioner of the In-
ternal Revenue Service shall enter into a contract 
with an independent reviewer to verify and validate 
the implementation plans (including the performance 
milestones and cost estimates included in such 
plans) developed for the Customer Account Data 
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Engine 2 and the Enterprise Case Management Sys-
tem. 
(2) DEADLINE FOR COMPLETION.—Such con-
tract shall require that such verification and valida-
tion be completed not later than the date which is 
1 year after the date of the enactment of this Act. 
(3) APPLICATION TO PHASES OF CADE 2.— 
(A) IN GENERAL.—Paragraphs (1) and (2) 
shall not apply to phase 1 of the Customer Ac-
count Data Engine 2 and shall apply separately 
to each other phase. 
(B) 
DEADLINE
FOR
COMPLETING 
PLANS.—Not later than 1 year after the date of 
the enactment of this Act, the Commissioner of 
the Internal Revenue Service shall complete the 
development of plans for all phases of the Cus-
tomer Account Data Engine 2. 
(C) DEADLINE
FOR
COMPLETION
OF 
VERIFICATION AND VALIDATION OF PLANS.—In 
the case of any phase after phase 2 of the Cus-
tomer Account Data Engine 2, paragraph (2) 
shall be applied by substituting ‘‘the date on 
which the plan for such phase was completed’’ 
for ‘‘the date of the enactment of this Act’’. 
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(c) COORDINATION OF IRS CIO AND CHIEF PRO-
CUREMENT OFFICER OF THE INTERNAL REVENUE SERV-
ICE.— 
(1) IN GENERAL.—The Chief Procurement Offi-
cer of the Internal Revenue Service shall— 
(A) identify all significant IRS information 
technology acquisitions and provide written no-
tification to the Internal Revenue Service Chief 
Information Officer (hereafter referred to in 
this subsection as the ‘‘IRS CIO’’) of each such 
acquisition in advance of such acquisition, and 
(B) regularly consult with the IRS CIO re-
garding acquisitions of information technology 
for the Internal Revenue Service, including 
meeting with the IRS CIO regarding such ac-
quisitions upon request. 
(2) SIGNIFICANT
IRS
INFORMATION
TECH-
NOLOGY ACQUISITIONS.—For purposes of this sub-
section, the term ‘‘significant IRS information tech-
nology acquisitions’’ means— 
(A) any acquisition of information tech-
nology for the Internal Revenue Service in ex-
cess of $1,000,000; and 
(B) such other acquisitions of information 
technology for the Internal Revenue Service (or 
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categories of such acquisitions) as the IRS CIO, 
in consultation with the Chief Procurement Of-
ficer of the Internal Revenue Service, may iden-
tify. 
(3) SCOPE.—Terms used in this subsection 
which are also used in section 7803(f) of the Inter-
nal Revenue Code of 1986 (as amended by sub-
section (a)) shall have the same meaning as when 
used in such section. 
SEC. 2102. INTERNET PLATFORM FOR FORM 1099 FILINGS. 
(a) IN GENERAL.—Not later than January 1, 2023, 
the Secretary of the Treasury or the Secretary’s delegate 
(hereafter referred to in this section as the ‘‘Secretary’’) 
shall make available an Internet website or other elec-
tronic media, with a user interface and functionality simi-
lar to the Business Services Online Suite of Services pro-
vided by the Social Security Administration, that will pro-
vide access to resources and guidance provided by the In-
ternal Revenue Service and will allow persons to— 
(1) prepare and file Forms 1099; 
(2) prepare Forms 1099 for distribution to re-
cipients other than the Internal Revenue Service; 
and 
(3) maintain a record of completed and sub-
mitted Forms 1099. 
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(b) ELECTRONIC SERVICES TREATED AS SUPPLE-
MENTAL; APPLICATION OF SECURITY STANDARDS.—The 
Secretary shall ensure that the services described in sub-
section (a)— 
(1) are a supplement to, and not a replacement 
for, other services provided by the Internal Revenue 
Service to taxpayers; and 
(2) comply with applicable security standards 
and guidelines. 
SEC. 2103. STREAMLINED CRITICAL PAY AUTHORITY FOR 
INFORMATION TECHNOLOGY POSITIONS. 
(a) IN GENERAL.—Subchapter A of chapter 80 is 
amended by adding at the end the following new section: 
‘‘SEC. 7812. STREAMLINED CRITICAL PAY AUTHORITY FOR 
INFORMATION TECHNOLOGY POSITIONS. 
‘‘In the case of any position which is critical to the 
functionality of the information technology operations of 
the Internal Revenue Service— 
‘‘(1) section 9503 of title 5, United States 
Code, shall be applied— 
‘‘(A) by substituting ‘during the period be-
ginning on the date of the enactment of section 
7812 of the Internal Revenue Code of 1986, 
and ending on September 30, 2023’ for ‘Before 
September 30, 2013 in subsection (a)’, 
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‘‘(B) without regard to subparagraph (B) 
of subsection (a)(1), and 
‘‘(C) by substituting ‘the date of the enact-
ment of the Taxpayer First Act of 2018’ for 
‘June 1, 1998’ in subsection (a)(6), 
‘‘(2) section 9504 of such title 5 shall be ap-
plied by substituting ‘During the period beginning 
on the date of the enactment of section 7812 of the 
Internal Revenue Code of 1986, and ending on Sep-
tember 30, 2023’ for ‘Before September 30, 2013’ 
each place it appears in subsections (a) and (b), and 
‘‘(3) section 9505 of such title shall be ap-
plied— 
‘‘(A) by substituting ‘During the period be-
ginning on the date of the enactment of section 
7812 of the Internal Revenue Code of 1986, 
and ending on September 30, 2023’ for ‘Before 
September 30, 2013’ in subsection (a), and 
‘‘(B) by substituting ‘the information tech-
nology operations’ for ‘significant functions’ in 
subsection (a).’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for subchapter A of chapter 80 is amended by adding at 
the end the following new item: 
‘‘Sec. 7812. Streamlined critical pay authority for information technology posi-
tions.’’. 
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Subtitle C—Modernization of Con-
sent-Based Income Verification 
System 
SEC. 2201. DISCLOSURE OF TAXPAYER INFORMATION FOR 
THIRD-PARTY INCOME VERIFICATION. 
(a) IN GENERAL.—Not later than 1 year after the 
close of the 2-year period described in subsection (d)(1), 
the Secretary of the Treasury or the Secretary’s delegate 
(hereafter referred to in this section as the ‘‘Secretary’’) 
shall implement a program to ensure that any qualified 
disclosure— 
(1) is fully automated and accomplished 
through the Internet; and 
(2) is accomplished in as close to real-time as 
is practicable. 
(b) QUALIFIED DISCLOSURE.—For purposes of this 
section, the term ‘‘qualified disclosure’’ means a disclosure 
under section 6103(c) of the Internal Revenue Code of 
1986 of returns or return information by the Secretary 
to a person seeking to verify the income or creditworthi-
ness of a taxpayer who is a borrower in the process of 
a loan application. 
(c) APPLICATION OF SECURITY STANDARDS.—The 
Secretary shall ensure that the program described in sub-
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section (a) complies with applicable security standards and 
guidelines. 
(d) USER FEE.— 
(1) IN GENERAL.—During the 2-year period be-
ginning on the first day of the 6th calendar month 
beginning after the date of the enactment of this 
Act, the Secretary shall assess and collect a fee for 
qualified disclosures (in addition to any other fee as-
sessed and collected for such disclosures) at such 
rates as the Secretary determines are sufficient to 
cover the costs related to implementing the program 
described in subsection (a), including the costs of 
any necessary infrastructure or technology. 
(2) DEPOSIT OF COLLECTIONS.—Amounts re-
ceived from fees assessed and collected under para-
graph (1) shall be deposited in, and credited to, an 
account solely for the purpose of carrying out the 
activities described in subsection (a). Such amounts 
shall be available to carry out such activities without 
need of further appropriation and without fiscal year 
limitation. 
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SEC. 2202. LIMIT REDISCLOSURES AND USES OF CONSENT- 
BASED DISCLOSURES OF TAX RETURN INFOR-
MATION. 
(a) IN GENERAL.—Section 6103(c) is amended by 
adding at the end the following: ‘‘Persons designated by 
the taxpayer under this subsection to receive return infor-
mation 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 per-
son without the express permission of, or request by, the 
taxpayer.’’. 
(b) 
APPLICATION
OF
PENALTIES.—Section 
6103(a)(3) is amended by inserting ‘‘subsection (c),’’ after 
‘‘return information under’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to disclosures made after the date 
of the enactment of this Act. 
Subtitle D—Expanded Use of 
Electronic Systems 
SEC. 2301. ELECTRONIC FILING OF RETURNS. 
(a) IN GENERAL.—Section 6011(e)(2)(A) is amended 
by striking ‘‘250’’ and inserting ‘‘the applicable number 
of’’. 
(b) APPLICABLE
NUMBER.—Section 6011(e) is 
amended by striking paragraph (5) and inserting the fol-
lowing new paragraphs: 
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‘‘(5) APPLICABLE NUMBER.— 
‘‘(A) IN GENERAL.—For purposes of para-
graph (2)(A), the applicable number shall be— 
‘‘(i) except as provided in subpara-
graph (B), in the case of calendar years 
before 2020, 250, 
‘‘(ii) in the case of calendar year 
2020, 100, and 
‘‘(iii) in the case of calendar years 
after 2020, 10. 
‘‘(B) SPECIAL RULE FOR PARTNERSHIPS 
FOR 2018 AND 2019.—In the case of a partner-
ship, for any calendar year before 2020, the ap-
plicable number shall be— 
‘‘(i) in the case of calendar year 2018, 
200, and 
‘‘(ii) in the case of calendar year 
2019, 150. 
‘‘(6) PARTNERSHIPS
REQUIRED
TO
FILE
ON 
MAGNETIC
MEDIA.—Notwithstanding 
paragraph 
(2)(A), the Secretary shall require partnerships hav-
ing more than 100 partners to file returns on mag-
netic media.’’. 
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(c) RETURNS FILED
BY
A TAX RETURN PRE-
PARER.—Section 6011(e)(3) is amended by adding at the 
end the following new subparagraph: 
‘‘(D) EXCEPTION
FOR
CERTAIN
PRE-
PARERS LOCATED IN AREAS WITHOUT INTER-
NET ACCESS.—The Secretary may waive the re-
quirement of subparagraph (A) if the Secretary 
determines, on the basis of an application by 
the tax return preparer, that the preparer can-
not meet such requirement by reason of being 
located in a geographic area which does not 
have access to internet service (other than dial- 
up or satellite service).’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall take effect on the date of the enactment 
of this Act. 
SEC. 2302. UNIFORM STANDARDS FOR THE USE OF ELEC-
TRONIC SIGNATURES FOR DISCLOSURE AU-
THORIZATIONS TO, AND OTHER AUTHORIZA-
TIONS OF, PRACTITIONERS. 
Section 6061(b)(3) is amended to read as follows: 
‘‘(3) PUBLISHED GUIDANCE.— 
‘‘(A) IN
GENERAL.—The Secretary shall 
publish guidance as appropriate to define and 
implement any waiver of the signature require-
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ments or any method adopted under paragraph 
(1). 
‘‘(B) ELECTRONIC SIGNATURES FOR DIS-
CLOSURE AUTHORIZATIONS TO, AND OTHER AU-
THORIZATIONS OF, PRACTITIONERS.—Not later 
than 6 months after the date of the enactment 
of this subparagraph, the Secretary shall pub-
lish guidance to establish uniform standards 
and procedures for the acceptance of taxpayers’ 
signatures appearing in electronic form with re-
spect to any request for disclosure of a tax-
payer’s return or return information under sec-
tion 6103(c) to a practitioner or any power of 
attorney granted by a taxpayer to a practi-
tioner. 
‘‘(C) PRACTITIONER.—For purposes of 
subparagraph (B), the term ‘practitioner’ 
means any individual in good standing who is 
regulated under section 330 of title 31, United 
States Code.’’. 
SEC. 2303. PAYMENT OF TAXES BY DEBIT AND CREDIT 
CARDS. 
Section 6311(d)(2) is amended by adding at the end 
the following: ‘‘The preceding sentence shall not apply to 
the extent that the Secretary ensures that any such fee 
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or other consideration is fully recouped by the Secretary 
in the form of fees paid to the Secretary by persons paying 
taxes imposed under subtitle A with credit, debit, or 
charge cards pursuant to such contract. Notwithstanding 
the preceding sentence, the Secretary shall seek to mini-
mize the amount of any fee or other consideration that 
the Secretary pays under any such contract.’’. 
SEC. 2304. REQUIREMENT THAT ELECTRONICALLY PRE-
PARED PAPER RETURNS INCLUDE SCAN-
NABLE CODE. 
(a) IN GENERAL.—Subsection (e) of section 6011, as 
amended by this Act, is amended by adding at the end 
the following new paragraph: 
‘‘(7) SPECIAL RULE FOR RETURNS PREPARED 
ELECTRONICALLY AND SUBMITTED ON PAPER.—The 
Secretary shall require that any return of tax which 
is prepared electronically, but is printed and filed on 
paper, bear a code which can, when scanned, convert 
such return to electronic format.’’. 
(b) CONFORMING AMENDMENT.—Paragraph (1) of 
section 6011(e) is amended by striking ‘‘paragraph (3)’’ 
and inserting ‘‘paragraphs (3) and (7)’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to returns of tax the due date for 
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which (determined without regard to extensions) is after 
December 31, 2020. 
SEC. 2305. AUTHENTICATION OF USERS OF ELECTRONIC 
SERVICES ACCOUNTS. 
Beginning 180 days after the date of the enactment 
of this Act, the Secretary of the Treasury (or the Sec-
retary’s delegate) shall verify the identity of any individual 
opening an e-Services account with the Internal Revenue 
Service before such individual is able to use the e-Services 
tools. 
Subtitle E—Other Provisions 
SEC. 2401. REPEAL OF PROVISION REGARDING CERTAIN 
TAX COMPLIANCE PROCEDURES AND RE-
PORTS. 
Section 2004 of the Internal Revenue Service Re-
structuring and Reform Act of 1998 (26 U.S.C. 6012 
note) is repealed. 
SEC. 2402. COMPREHENSIVE TRAINING STRATEGY. 
Not later than 1 year after the date of the enactment 
of this Act, the Commissioner of Internal Revenue shall 
submit to Congress a written report providing a com-
prehensive training strategy for employees of the Internal 
Revenue Service, including— 
(1) a plan to streamline current training proc-
esses, including an assessment of the utility of fur-
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ther consolidating internal training programs, tech-
nology, and funding; 
(2) a plan to develop annual training regarding 
taxpayer rights, including the role of the Office of 
the Taxpayer Advocate, for employees that interface 
with taxpayers and their managers; 
(3) a plan to improve technology-based training; 
(4) proposals to— 
(A) focus employee training on early, fair, 
and efficient resolution of taxpayer disputes for 
employees that interface with taxpayers and 
their managers; and 
(B) ensure consistency of skill development 
and employee evaluation throughout the Inter-
nal Revenue Service; and 
(5) a thorough assessment of the funding nec-
essary to implement such strategy. 
TITLE III—MISCELLANEOUS 
PROVISIONS 
Subtitle A—Reform of Laws Gov-
erning Internal Revenue Serv-
ice Employees 
SEC. 3001. ELECTRONIC RECORD RETENTION. 
(a) RETENTION OF RECORDS.— 
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(1) IN GENERAL.—Email records of the Inter-
nal Revenue Service shall be retained in an appro-
priate electronic system that supports records man-
agement and litigation requirements, including the 
capability to identify, retrieve, and retain the 
records, in accordance with the requirements de-
scribed in paragraph (2). 
(2) REQUIREMENTS.— 
(A) PRIOR TO CERTIFICATION.—The Com-
missioner of Internal Revenue and the Chief 
Counsel for the Internal Revenue Service shall 
retain all email records generated on or after 
the date of the enactment of this Act and be-
fore the date on which the Treasury Inspector 
General for Tax Administration makes the cer-
tification under subsection (c)(1). 
(B) PRINCIPAL OFFICERS AND SPECIFIED 
EMPLOYEES.—Not later than December 31, 
2019, the Commissioner of Internal Revenue 
and the Chief Counsel for the Internal Revenue 
Service shall maintain email records of all prin-
cipal officers and specified employees of the In-
ternal Revenue Service for a period of not less 
than 15 years beginning on the date such 
record was generated. 
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(b) TRANSMISSION OF RECORDS TO THE NATIONAL 
ARCHIVES.—Not later than 15 years after the date on 
which an email record of a principal officer or specified 
employee of the Internal Revenue Service is generated, the 
Commissioner of Internal Revenue and the Chief Counsel 
for the Internal Revenue Service shall transfer such email 
record to the Archivist of the United States. 
(c) COMPLIANCE.— 
(1) CERTIFICATION.—On the date that the 
Treasury Inspector General for Tax Administration 
determines that the Internal Revenue Service has a 
program in place that complies with the require-
ments of subsections (a)(2)(B) and (b), the Treas-
ury Inspector General for Tax Administration shall 
certify to the Committee on Ways and Means of the 
House of Representatives and the Committee on Fi-
nance of the Senate that the Internal Revenue Serv-
ice is in compliance with such requirements. 
(2) REPORTS.— 
(A) INTERIM REPORT.—Not later than De-
cember 31, 2019, the Treasury Inspector Gen-
eral for Tax Administration shall submit a re-
port to the Committee on Ways and Means of 
the House of Representatives and the Com-
mittee on Finance of the Senate on the steps 
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being taken by the Commissioner of Internal 
Revenue and the Chief Counsel for the Internal 
Revenue Service to comply with the require-
ments of subsections (a)(2)(B) and (b). 
(B) FINAL REPORT.—Not later than April 
1, 2020, the Treasury Inspector General for 
Tax Administration shall submit a report to the 
Committee on Ways and Means of the House of 
Representatives and the Committee on Finance 
of the Senate describing whether the Internal 
Revenue Service is in compliance with the re-
quirements of subsections (a)(2)(B) and (b). 
(d) DEFINITIONS.—For purposes of this section— 
(1) PRINCIPAL OFFICER.—The term ‘‘principal 
officer’’ means, with respect to the Internal Revenue 
Service— 
(A) any employee whose position is listed 
under the Internal Revenue Service in the most 
recent version of the United States Government 
Manual published by the Office of the Federal 
Register; 
(B) any employee who is a senior staff 
member reporting directly to the Commissioner 
of Internal Revenue or the Chief Counsel for 
the Internal Revenue Service; and 
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(C) any associate counsel, deputy counsel, 
or division head in the Office of the Chief 
Counsel for the Internal Revenue Service. 
(2) SPECIFIED EMPLOYEE.—The term ‘‘speci-
fied employee’’ means, with respect to the Internal 
Revenue Service, any employee who— 
(A) holds a Senior Executive Service posi-
tion (as defined in section 3132 of title 5, 
United States Code) in the Internal Revenue 
Service or the Office of Chief Counsel for the 
Internal Revenue Service; and 
(B) is not a principal officer of the Inter-
nal Revenue Service. 
SEC. 3002. PROHIBITION ON REHIRING ANY EMPLOYEE OF 
THE INTERNAL REVENUE SERVICE WHO WAS 
INVOLUNTARILY SEPARATED FROM SERVICE 
FOR MISCONDUCT. 
(a) IN GENERAL.—Section 7804 is amended by add-
ing at the end the following new subsection: 
‘‘(d) PROHIBITION ON REHIRING EMPLOYEES INVOL-
UNTARILY SEPARATED.—The Commissioner may not hire 
any individual previously employed by the Commissioner 
who was removed for misconduct under this subchapter 
or chapter 43 or chapter 75 of title 5, United States Code, 
or whose employment was terminated under section 1203 
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of the Internal Revenue Service Restructuring and Reform 
Act of 1998 (26 U.S.C. 7804 note).’’. 
(b) EFFECTIVE DATE.—The amendment made by 
subsection (a) shall apply with respect to the hiring of em-
ployees after the date of the enactment of this Act. 
SEC. 3003. NOTIFICATION OF UNAUTHORIZED INSPECTION 
OR DISCLOSURE OF RETURNS AND RETURN 
INFORMATION. 
(a) IN GENERAL.—Subsection (e) of section 7431 is 
amended by adding at the end the following new sen-
tences: ‘‘The Secretary shall also notify such taxpayer if 
the Internal Revenue Service or a Federal or State agency 
(upon notice to the Secretary by such Federal or State 
agency) proposes an administrative determination as to 
disciplinary or adverse action against an employee arising 
from the employee’s unauthorized inspection or disclosure 
of the taxpayer’s return or return information. The notice 
described in this subsection shall include the date of the 
unauthorized inspection or disclosure and the rights of the 
taxpayer under such administrative determination.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to determinations proposed after 
the date which is 180 days after the date of the enactment 
of this Act. 
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Subtitle B—Provisions Relating to 
Exempt Organizations 
SEC. 3101. MANDATORY E-FILING BY EXEMPT ORGANIZA-
TIONS. 
(a) IN GENERAL.—Section 6033 is amended by re-
designating subsection (n) as subsection (o) and by insert-
ing after subsection (m) the following new subsection: 
‘‘(n) MANDATORY ELECTRONIC FILING.—Any orga-
nization required to file a return under this section shall 
file such return in electronic form.’’. 
(b) CONFORMING AMENDMENT.—Paragraph (7) of 
section 527(j) is amended by striking ‘‘if the organization 
has’’ and all that follows through ‘‘such calendar year’’. 
(c) INSPECTION OF ELECTRONICALLY FILED AN-
NUAL RETURNS.—Subsection (b) of section 6104 is 
amended by adding at the end the following: ‘‘Any annual 
return required to be filed electronically under section 
6033(n) shall be made available by the Secretary to the 
public as soon as practicable in a machine readable for-
mat.’’. 
(d) EFFECTIVE DATE.— 
(1) IN GENERAL.—Except as provided in para-
graph (2), the amendments made by this section 
shall apply to taxable years beginning after the date 
of the enactment of this Act. 
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(2) TRANSITIONAL RELIEF.— 
(A) SMALL ORGANIZATIONS.— 
(i) IN GENERAL.—In the case of any 
small organizations, or any other organiza-
tions for which the Secretary of the Treas-
ury or the Secretary’s delegate (hereafter 
referred to in this paragraph as the ‘‘Sec-
retary’’) determines the application of the 
amendments made by this section would 
cause undue burden without a delay, the 
Secretary may delay the application of 
such amendments, but such delay shall not 
apply to any taxable year beginning on or 
after the date 2 years after of the enact-
ment of this Act. 
(ii) SMALL ORGANIZATION.—For pur-
poses of clause (i), the term ‘‘small organi-
zation’’ means any organization— 
(I) the gross receipts of which for 
the 
taxable 
year 
are 
less 
than 
$200,000; and 
(II) the aggregate gross assets of 
which at the end of the taxable year 
are less than $500,000. 
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(B) ORGANIZATIONS
FILING
FORM 990– 
T.—In the case of any organization described 
in section 511(a)(2) of the Internal Revenue 
Code of 1986 which is subject to the tax im-
posed by section 511(a)(1) of such Code on its 
unrelated business taxable income, or any orga-
nization required to file a return under section 
6033 of such Code and include information 
under subsection (e) thereof, the Secretary may 
delay the application of the amendments made 
by this section, but such delay shall not apply 
to any taxable year beginning on or after the 
date 2 years after of the enactment of this Act. 
SEC. 3102. NOTICE REQUIRED BEFORE REVOCATION OF 
TAX EXEMPT STATUS FOR FAILURE TO FILE 
RETURN. 
(a) IN GENERAL.—Section 6033(j)(1) is amended by 
striking ‘‘If an organization’’ and inserting the following: 
‘‘(A) NOTICE.— 
‘‘(i) IN GENERAL.—After an organiza-
tion described in subsection (a)(1) or (i) 
fails to file the annual return or notice re-
quired under either subsection for 2 con-
secutive years, the Secretary shall notify 
the organization— 
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‘‘(I) that the Internal Revenue 
Service has no record of such a return 
or notice from such organization for 2 
consecutive years, and 
‘‘(II) about the revocation that 
will occur under subparagraph (B) if 
the organization fails to file such a re-
turn or notice by the due date for the 
next such return or notice required to 
be filed. 
The notification under the preceding sen-
tence shall include information about how 
to comply with the filing requirements 
under subsection (a)(1) and (i). 
‘‘(B) REVOCATION.—If an organization’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall apply to failures to file returns or notices 
for 2 consecutive years if the return or notice for the sec-
ond year is required to be filed after December 31, 2018. 
Subtitle C—Tax Court 
SEC. 3301. DISQUALIFICATION OF JUDGE OR MAGISTRATE 
JUDGE OF THE TAX COURT. 
(a) IN GENERAL.—Part II of subchapter C of chap-
ter 76 is amended by adding at the end the following new 
section: 
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‘‘SEC. 7467. DISQUALIFICATION OF JUDGE OR MAGISTRATE 
JUDGE OF THE TAX COURT. 
‘‘Section 455 of title 28, United States Code, shall 
apply to judges and magistrate judges of the Tax Court 
and to proceedings of the Tax Court.’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for such part is amended by adding at the end the fol-
lowing new item: 
‘‘Sec. 7467. Disqualification of judge or magistrate judge of the Tax Court.’’. 
SEC. 3302. OPINIONS AND JUDGMENTS. 
(a) IN GENERAL.—Section 7459 is amended by strik-
ing all that precedes subsection (c) and inserting the fol-
lowing: 
‘‘SEC. 7459. OPINIONS AND JUDGMENTS. 
‘‘(a) REQUIREMENT.—An opinion upon any pro-
ceeding instituted before the Tax Court and a judgment 
thereon shall be made as quickly as practicable. The judg-
ment shall be made by a judge in accordance with the 
opinion of the Tax Court, and such judgment so made 
shall, when entered, be the judgment of the Tax Court. 
‘‘(b) INCLUSION OF FINDINGS OF FACT IN OPIN-
ION.—It shall be the duty of the Tax Court and of each 
division to include in its opinion or memorandum opinion 
upon any proceeding, its findings of fact. The Tax Court 
shall issue in writing all of its findings of fact, opinions, 
and memorandum opinions. Subject to such conditions as 
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the Tax Court may by rule provide, the requirements of 
this subsection and of section 7460 are met if findings 
of fact or opinion are stated orally and recorded in the 
transcript of the proceedings.’’. 
(b) REFERENCES.—Section 7459 is amended by re-
designating subsection (g) as subsection (h) and by insert-
ing after subsection (f) the following new subsection: 
‘‘(g) REFERENCES.—Any reference in this title to a 
decision or report of the Tax Court shall be treated as 
a reference to a judgment or opinion of the Tax Court, 
respectively.’’. 
(c) CONFORMING AMENDMENT.—The item relating 
to section 7459 in the table of sections for part II of sub-
chapter C of chapter 76 is amended to read as follows: 
‘‘Sec. 7459. Opinions and judgments.’’. 
(d) CONTINUING EFFECT OF LEGAL DOCUMENTS.— 
All orders, decisions, reports, rules, permits, agreements, 
grants, contracts, certificates, licenses, registrations, privi-
leges, and other administrative actions, in connection with 
the Tax Court, which are in effect at the time this section 
takes effect, or were final before the effective date of this 
section and are to become effective on or after the effective 
date of this section, shall continue in effect according to 
their terms until modified, terminated, superseded, set 
aside, or revoked in accordance with law by the Tax Court. 
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SEC. 3303. TITLE OF SPECIAL TRIAL JUDGE CHANGED TO 
MAGISTRATE JUDGE OF THE TAX COURT. 
(a) IN GENERAL.—Section 7443A is amended— 
(1) by striking ‘‘special trial judges’’ in sub-
sections (a) and (e) and inserting ‘‘magistrate 
judges of the Tax Court’’; 
(2) by striking ‘‘special trial judges of the 
court’’ in subsection (b) and inserting ‘‘magistrate 
judges of the Tax Court’’; and 
(3) by striking ‘‘special trial judge’’ in sub-
sections (c) and (d) and inserting ‘‘magistrate judge 
of the Tax Court’’. 
(b) CONFORMING AMENDMENTS.— 
(1) The heading of section 7443A is amended 
by striking ‘‘SPECIAL TRIAL JUDGES’’ and insert-
ing 
‘‘MAGISTRATE
JUDGES
OF
THE
TAX 
COURT’’. 
(2) The heading of section 7443A(b) is amend-
ed by striking ‘‘SPECIAL TRIAL JUDGES’’ and insert-
ing ‘‘MAGISTRATE JUDGES OF THE TAX COURT’’. 
(3) The item relating to section 7443A in the 
table of sections for part I of subchapter C of chap-
ter 76 is amended to read as follows: 
‘‘Sec. 7443A. Magistrate judges of the Tax Court.’’. 
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(4) The heading of section 7448 is amended by 
striking ‘‘SPECIAL TRIAL JUDGES’’ and inserting 
‘‘MAGISTRATE JUDGES OF THE TAX COURT’’. 
(5) Section 7448 is amended— 
(A) by striking ‘‘special trial judge’s’’ each 
place it appears in subsections (a)(6), (c)(1), 
(d), and (m)(1) and inserting ‘‘magistrate judge 
of the Tax Court’s’’; and 
(B) by striking ‘‘special trial judge’’ each 
place it appears other than in subsection (n) 
and inserting ‘‘magistrate judge of the Tax 
Court’’. 
(6) Section 7448(n) is amended— 
(A) by striking ‘‘special trial judge which 
are allowable’’ and inserting ‘‘magistrate judge 
of the Tax Court which are allowable’’; and 
(B) by striking ‘‘special trial judge of the 
Tax Court’’ both places it appears and inserting 
‘‘magistrate judge of the Tax Court’’. 
(7) The heading of section 7448(b)(2) is 
amended by striking ‘‘SPECIAL TRIAL JUDGES’’ and 
inserting ‘‘MAGISTRATE
JUDGES
OF
THE
TAX 
COURT’’. 
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(8) The item relating to section 7448 in the 
table of sections for part I of subchapter C of chap-
ter 76 is amended to read as follows: 
‘‘Sec. 7448. Annuities to surviving spouses and dependent children of judges 
and magistrate judges of the Tax Court.’’. 
(9) Section 7456(a) is amended— 
(A) by striking ‘‘special trial judge’’ each 
place it appears and inserting ‘‘magistrate 
judge’’; and 
(B) by striking ‘‘(or by the clerk’’ and in-
serting ‘‘of the Tax Court (or by the clerk’’. 
(10) Section 7466(a) is amended by striking 
‘‘special trial judge’’ and inserting ‘‘magistrate 
judge’’. 
(11) Section 7470A is amended by striking 
‘‘special trial judges’’ both places it appears in sub-
sections (a) and (b) and inserting ‘‘magistrate 
judges’’. 
(12) Section 7471(a)(2)(A) is amended by 
striking ‘‘special trial judges’’ and inserting ‘‘mag-
istrate judges’’. 
(13) Section 7471(c) is amended— 
(A) by striking ‘‘SPECIAL TRIAL JUDGES’’ 
in the heading and inserting ‘‘MAGISTRATE 
JUDGES OF THE TAX COURT’’; and 
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(B) by striking ‘‘special trial judges’’ and 
inserting ‘‘magistrate judges’’. 
SEC. 3304. REPEAL OF DEADWOOD RELATED TO BOARD OF 
TAX APPEALS. 
(a) Section 7459, as amended by this Act, is amended 
by striking subsection (f) and by redesignating subsections 
(g) and (h) as subsections (f) and (g), respectively. 
(b) Section 7447(a)(3) is amended to read as follows: 
‘‘(3) In any determination of length of service 
as judge or as a judge of the Tax Court of the 
United States there shall be included all periods 
(whether or not consecutive) during which an indi-
vidual served as judge.’’. 
Passed the House of Representatives December 20, 
2018. 
Attest: 
KAREN L. HAAS, 
Clerk. 
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