235 
lated 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 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 pre-
ceding sentence, the Secretary shall seek to minimize 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
236 
paper, bear a code which can, when scanned, convert 
such return to electronic format.’’. 
(b) CONFORMING AMENDMENT.—Paragraph (1) of sec-
tion 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 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 Secretary’s 
delegate) shall verify the identity of any individual opening 
an e-Services account with the Internal Revenue Service be-
fore 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 Restruc-
turing and Reform Act of 1998 (26 U.S.C. 6012 note) is 
repealed.
237 
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 sub-
mit to Congress a written report providing a comprehensive 
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 further 
consolidating internal training programs, technology, 
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 Internal 
Revenue Service, and 
(5) a thorough assessment of the funding nec-
essary to implement such strategy.
238 
TITLE III—MISCELLANEOUS 
PROVISIONS 
Subtitle A—Reform of Laws Gov-
erning Internal Revenue Service 
Employees 
SEC. 3001. ELECTRONIC RECORD RETENTION. 
(a) RETENTION OF RECORDS.— 
(1) IN GENERAL.—Email records of the Internal 
Revenue Service shall be retained in an appropriate 
electronic system that supports records management 
and litigation requirements, including the capability 
to identify, retrieve, and retain the records, in accord-
ance with the requirements described 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 before the 
date on which the Treasury Inspector General for 
Tax Administration makes the certification 
under subsection (c)(1). 
(B) PRINCIPAL
OFFICERS
AND
SPECIFIED 
EMPLOYEES.—Not later than December 31, 2019,
239 
the Commissioner of Internal Revenue and the 
Chief Counsel for the Internal Revenue Service 
shall maintain email records of all principal of-
ficers and specified employees of the Internal 
Revenue Service for a period of not less than 15 
years beginning on the date such record was gen-
erated. 
(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 Commis-
sioner 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 Treas-
ury Inspector General for Tax Administration deter-
mines that the Internal Revenue Service has a pro-
gram in place that complies with the requirements of 
subsections (a)(2)(B) and (b), the Treasury Inspector 
General for Tax Administration shall certify to the 
Committee on Ways and Means of the House of Rep-
resentatives and the Committee on Finance of the 
Senate that the Internal Revenue Service is in com-
pliance with such requirements.
240 
(2) REPORTS.— 
(A) INTERIM REPORT.—Not later than De-
cember 31, 2019, 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 Fi-
nance of the Senate on the steps being taken by 
the Commissioner of Internal Revenue and the 
Chief Counsel for the Internal Revenue Service to 
comply with the requirements 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
241 
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 
(C) any associate counsel, deputy counsel, 
or division head in the Office of the Chief Coun-
sel for the Internal Revenue Service. 
(2) SPECIFIED EMPLOYEE.—The term ‘‘specified 
employee’’ means, with respect to the Internal Rev-
enue 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 Rev-
enue Service; and 
(B) is not a principal officer of the Internal 
Revenue Service.
242 
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 adding 
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 of 
the Internal Revenue Service Restructuring and Reform Act 
of 1998 (26 U.S.C. 7804 note).’’. 
(b) EFFECTIVE DATE.—The amendment made by sub-
section (a) shall apply with respect to the hiring of employ-
ees 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 sentences: 
‘‘The Secretary shall also notify such taxpayer if the Inter-
nal 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 discipli-
243 
nary 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 de-
scribed in this subsection shall include the date of the unau-
thorized inspection or disclosure and the rights of the tax-
payer 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. 
Subtitle B—Provisions Relating to 
Exempt Organizations 
SEC. 3101. MANDATORY E-FILING BY EXEMPT ORGANIZA-
TIONS. 
(a) IN GENERAL.—Section 6033 is amended by redes-
ignating subsection (n) as subsection (o) and by inserting 
after subsection (m) the following new subsection: 
‘‘(n) MANDATORY ELECTRONIC FILING.—Any organi-
zation required to file a return under this section shall file 
such return in electronic form.’’. 
(b) CONFORMING AMENDMENT.—Paragraph (7) of sec-
tion 527(j) is amended by striking ‘‘if the organization has’’ 
and all that follows through ‘‘such calendar year’’. 
(c) INSPECTION OF ELECTRONICALLY FILED ANNUAL 
RETURNS.—Subsection (b) of section 6104 is amended by
244 
adding at the end the following: ‘‘Any annual return re-
quired 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 format.’’. 
(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. 
(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 re-
ferred 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 enactment of 
this Act.
245 
(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. 
(B) ORGANIZATIONS FILING FORM 990–T.— 
In the case of any organization described in sec-
tion 511(a)(2) of the Internal Revenue Code of 
1986 which is subject to the tax imposed by sec-
tion 511(a)(1) of such Code on its unrelated 
business taxable income, or any organization re-
quired to file a return under section 6033 of such 
Code and include information under subsection 
(e) thereof, the Secretary may delay the applica-
tion 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.
246 
SEC. 3102. NOTICE REQUIRED BEFORE REVOCATION OF TAX 
EXEMPT STATUS FOR FAILURE TO FILE RE-
TURN. 
(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 consecu-
tive years, the Secretary shall notify the or-
ganization— 
‘‘(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).
248 
‘‘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 opin-
ion 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 OPINION.— 
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 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 redes-
ignating subsection (g) as subsection (h) and by inserting 
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, respec-
tively.’’.
249 
(c) CONFORMING AMENDMENT.—The item relating to 
section 7459 in the table of sections for part II of subchapter 
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. 
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’’.
250 
(b) CONFORMING AMENDMENTS.— 
(1) The heading of section 7443A is amended by 
striking ‘‘SPECIAL TRIAL JUDGES’’ and inserting 
‘‘MAGISTRATE JUDGES OF THE TAX COURT’’. 
(2) The heading of section 7443A(b) is amended 
by striking ‘‘SPECIAL TRIAL JUDGES’’ and inserting 
‘‘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 chapter 
76 is amended to read as follows: 
‘‘Sec. 7443A. Magistrate judges of the Tax Court.’’. 
(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
251 
(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’’. 
(8) The item relating to section 7448 in the table 
of sections for part I of subchapter C of chapter 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 ‘‘spe-
cial trial judges’’ both places it appears in subsections 
(a) and (b) and inserting ‘‘magistrate judges’’. 
(12) Section 7471(a)(2)(A) is amended by strik-
ing ‘‘special trial judges’’ and inserting ‘‘magistrate 
judges’’.
252 
(13) Section 7471(c) is amended— 
(A) by striking ‘‘SPECIAL TRIAL JUDGES’’ 
in the heading and inserting ‘‘MAGISTRATE 
JUDGES OF THE TAX COURT’’, and 
(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 individual served as 
judge.’’. 
Attest: 
Clerk.
115TH CONGRESS 
2D SESSION 
H.R. 88 
HOUSE AMENDMENT TO 
SENATE AMENDMENT