IB 
Union Calendar No. 488 
115TH CONGRESS 
2D SESSION 
H. R. 5444 
[Report No. 115–637, Part I] 
To amend the Internal Revenue Code of 1986 to modernize and improve 
the Internal Revenue Service, and for other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
APRIL 10, 2018 
Ms. JENKINS of Kansas (for herself and Mr. LEWIS of Georgia) introduced 
the following bill; which was referred to the Committee on Ways and 
Means, and in addition to the Committee on Financial Services, for a pe-
riod to be subsequently determined by the Speaker, in each case for con-
sideration of such provisions as fall within the jurisdiction of the com-
mittee concerned 
APRIL 13, 2018 
Additional sponsors: Mr. MCGOVERN, Mr. SESSIONS, and Mr. MARCHANT 
APRIL 13, 2018 
Reported from the Committee on Ways and Means with an amendment 
[Strike out all after the enacting clause and insert the part printed in italic] 
APRIL 13, 2018 
The Committee on Financial Services discharged; committed to the Committee 
of the Whole House on the State of the Union and ordered to be printed 
[For text of introduced bill, see copy of bill as introduced on April 10, 2018] 
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A BILL 
To amend the Internal Revenue Code of 1986 to modernize 
and improve the Internal Revenue Service, and for other 
purposes. 
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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 
‘‘Taxpayer First Act’’. 
(b) AMENDMENT OF 1986 CODE.—Except as otherwise 
expressly provided, whenever in this Act an amendment or 
repeal is expressed in terms of an amendment to, or repeal 
of, a section or other provision, the reference shall be consid-
ered to be made to a section or other provision of the Inter-
nal Revenue Code of 1986. 
(c) TABLE OF CONTENTS.—The table of contents of this 
Act is as follows: 
Sec. 1. Short title; etc. 
TITLE I—INDEPENDENT APPEALS PROCESS 
Sec. 101. Establishment of Internal Revenue Service Independent Office of Ap-
peals. 
TITLE II—IMPROVED SERVICE 
Sec. 201. Comprehensive customer service strategy. 
Sec. 202. IRS Free File Program. 
Sec. 203. Low-income exception for payments otherwise required in connection 
with a submission of an offer-in-compromise. 
TITLE III—SENSIBLE ENFORCEMENT 
Sec. 301. Internal Revenue Service seizure requirements with respect to struc-
turing transactions. 
Sec. 302. Exclusion of interest received in action to recover property seized by the 
Internal Revenue Service based on structuring transaction. 
Sec. 303. Clarification of equitable relief from joint liability. 
Sec. 304. Modification of procedures for issuance of third-party summons. 
Sec. 305. Establishment of income threshold for referral to private debt collection. 
Sec. 306. Reform of notice of contact of third parties. 
Sec. 307. Modification of authority to issue designated summons. 
Sec. 308. Limitation on access of non-Internal Revenue Service employees to re-
turns and return information. 
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TITLE IV—ORGANIZATIONAL MODERNIZATION 
Sec. 401. Modification of title of Commissioner of Internal Revenue and related 
officials. 
Sec. 402. Office of the National Taxpayer Advocate. 
Sec. 403. Elimination of IRS Oversight Board. 
Sec. 404. Modernization of Internal Revenue Service organizational structure. 
TITLE V—TAX COURT 
Sec. 501. Disqualification of judge or magistrate judge of the Tax Court. 
Sec. 502. Opinions and judgments. 
Sec. 503. Title of special trial judge changed to magistrate judge of the Tax 
Court. 
Sec. 504. Repeal of deadwood related to Board of Tax Appeals. 
TITLE I—INDEPENDENT 
APPEALS PROCESS 
SEC. 101. ESTABLISHMENT OF INTERNAL REVENUE SERV-
ICE INDEPENDENT OFFICE OF APPEALS. 
(a) IN GENERAL.—Section 7803 is amended by adding 
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 official 
to be known as the ‘Chief of Appeals’. The Chief 
of Appeals shall report directly to the Adminis-
trator of the Internal Revenue Service and shall 
be entitled to compensation at the same rate as 
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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 Appeals 
shall be appointed by the Administrator of the 
Internal Revenue Service without regard to the 
provisions 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 expe-
rience 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 
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, 
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‘‘(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 process 
described in paragraph (3) shall be generally avail-
able to all taxpayers. 
‘‘(5) LIMITATION ON DESIGNATION OF CASES AS 
NOT ELIGIBLE FOR REFERRAL TO INDEPENDENT OF-
FICE OF APPEALS.— 
‘‘(A) IN GENERAL.—If any taxpayer which 
is in receipt of notice of deficiency authorized 
under section 6212 requests referral to the Inter-
nal Revenue Service Independent Office of Ap-
peals and such request is denied, the Adminis-
trator of the Internal Revenue Service shall pro-
vide such taxpayer a written notice which— 
‘‘(i) provides a detailed description of 
the facts involved, the basis for the decision 
to deny the request, and a detailed expla-
nation of how the basis of such decision ap-
plies to such facts, and 
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‘‘(ii) describes the procedures pro-
scribed under subparagraph (C) for pro-
testing the decision to deny the request. 
‘‘(B) REPORT TO CONGRESS.—The Admin-
istrator of the Internal Revenue Service shall 
submit a written report to Congress on an an-
nual basis which includes the number of requests 
described in subparagraph (A) which were de-
nied and the reasons (described by category) that 
such requests were denied. 
‘‘(C) PROCEDURES
FOR
PROTESTING
DE-
NIAL OF REQUEST.—The Administrator of the 
Internal Revenue Service shall prescribe proce-
dures for protesting to the Administrator of the 
Internal Revenue Service (personally and not 
through any delegate) a denial of a request de-
scribed in subparagraph (A). 
‘‘(D) NOT APPLICABLE TO FRIVOLOUS POSI-
TIONS.—This paragraph shall not apply to a re-
quest for referral to the Internal Revenue Service 
Independent Office of Appeals which is denied on 
the basis that the issue involved is a frivolous po-
sition (within the meaning of section 6702(c)). 
‘‘(6) STAFF.— 
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‘‘(A) IN GENERAL.—All personnel in the In-
ternal Revenue Service Independent Office of Ap-
peals shall report to the Chief of Appeals. 
‘‘(B) ACCESS TO STAFF OF OFFICE OF THE 
CHIEF
COUNSEL.—The Chief of Appeals shall 
have authority to obtain legal assistance and ad-
vice from the staff of the Office of the Chief 
Counsel. The Chief Counsel shall ensure that 
such assistance and advice is provided by staff of 
the Office of the Chief Counsel who were not in-
volved in the case with respect to which such as-
sistance and advice is sought and who are not 
involved in preparing such case for litigation. 
‘‘(7) ACCESS TO CASE FILES.— 
‘‘(A) IN GENERAL.—In the case of any spec-
ified taxpayer with respect to which a conference 
with the Internal Revenue Service Independent 
Office of Appeals has been scheduled, the Chief of 
Appeals shall ensure that such taxpayer is pro-
vided access to the nonprivileged portions of the 
case file on record regarding the disputed issues 
(other than documents provided by the taxpayer 
to the Internal Revenue Service) not later than 
10 days before the date of such conference. 
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‘‘(B) TAXPAYER
ELECTION
TO
EXPEDITE 
CONFERENCE.—If the taxpayer so elects, sub-
paragraph (A) shall be applied by substituting 
‘the date of such conference’ for ‘10 days before 
the date of such conference’. 
‘‘(C) SPECIFIED TAXPAYER.—For purposes 
of this paragraph— 
‘‘(i) IN GENERAL.—The term ‘specified 
taxpayer’ means— 
‘‘(I) in the case of any taxpayer 
who is a natural person, a taxpayer 
whose adjusted gross income does not 
exceed $400,000, and 
‘‘(II) in the case of any other tax-
payer, a taxpayer whose gross receipts 
do not exceed $5,000,000. 
‘‘(ii) 
AGGREGATION
RULE.—Rules 
similar to the rules of section 448(c)(2) 
shall apply for purposes of clause (i)(II).’’. 
(b) CONFORMING AMENDMENTS.— 
(1) The following provisions are each amended 
by striking ‘‘Internal Revenue Service Office of Ap-
peals’’ and inserting ‘‘Internal Revenue Service Inde-
pendent Office of Appeals’’: 
(A) Section 6015(c)(4)(B)(ii)(I). 
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(B) Section 6320(b)(1). 
(C) Subsections (b)(1) and (d)(3) of section 
6330. 
(D) Section 6603(d)(3)(B). 
(E) Section 6621(c)(2)(A)(i). 
(F) Section 7122(e)(2). 
(G) Subsections (a), (b)(1), (b)(2), and 
(c)(1) of section 7123. 
(H) Subsections (c)(7)(B)(i, and (g)(2)(A) 
of section 7430. 
(I) Section 7522(b)(3). 
(J) Section 7612(c)(2)(A). 
(2) Section 7430(c)(2) is amended by striking 
‘‘Internal Revenue Service Office of Appeals’’ each 
place it appears and inserting ‘‘Internal Revenue 
Service Independent Office of Appeals’’. 
(3) The heading of section 6330(d)(3) is amended 
by inserting ‘‘INDEPENDENT’’ after ‘‘IRS’’. 
(c) OTHER REFERENCES.—Any reference in any pro-
vision of law, or regulation or other guidance, to the Inter-
nal Revenue Service Office of Appeals shall be treated as 
a reference to the Internal Revenue Service Independent Of-
fice of Appeals. 
(d) SAVINGS PROVISIONS.—Rules similar to the rules 
of paragraphs (2) through (6) of section 1001(b) of the In-
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ternal Revenue Service Restructuring and Reform Act of 
1998 shall apply for purposes of this section (and the 
amendments made by this section). 
(e) EFFECTIVE DATE.— 
(1) IN GENERAL.—Except as otherwise provided 
in this subsection, the amendments made by this sec-
tion shall take effect on the date of the enactment of 
this Act. 
(2) ACCESS TO CASE FILES.—Section 7803(e)(7) 
of the Internal Revenue Code of 1986, as added by 
subsection (a), shall apply to conferences occurring 
after the date which is 1 year after the date of the en-
actment of this Act. 
TITLE II—IMPROVED SERVICE 
SEC. 201. COMPREHENSIVE CUSTOMER SERVICE STRATEGY. 
(a) IN GENERAL.—Not later than the date which is 
1 year after the date of the enactment of this Act, the Sec-
retary of the Treasury, after consultation with the National 
Taxpayer Advocate, shall submit to Congress a written com-
prehensive customer service strategy for the Internal Rev-
enue Service. Such strategy shall include— 
(1) a plan to provide assistance to taxpayers 
that is secure, designed to meet reasonable taxpayer 
expectations, and adopts appropriate best practices of 
customer service provided in the private sector, in-
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cluding online services, telephone call back services, 
and training of employees providing customer serv-
ices, 
(2) a thorough assessment of the services that the 
Internal Revenue Service can co-locate with other 
Federal services or offer as self-service options, 
(3) proposals to improve Internal Revenue Serv-
ice customer service in the short term (the current 
and following fiscal year), medium term (approxi-
mately 3 to 5 fiscal years), and long term (approxi-
mately 10 fiscal years), 
(4) a plan to update guidance and training ma-
terials for customer service employees of the Internal 
Revenue Service, including the Internal Revenue 
Manual, to reflect such strategy, and 
(5) identified metrics and benchmarks for quan-
titatively measuring the progress of the Internal Rev-
enue Service in implementing such strategy. 
(b) UPDATED
GUIDANCE
AND
TRAINING
MATE-
RIALS.—Not later than 2 years after the date of the enact-
ment of this Act, the Secretary of the Treasury shall make 
available the updated guidance and training materials de-
scribed in subsection (a)(4) (including the Internal Revenue 
Manual). Such updated guidance and training materials 
(including the Internal Revenue Manual) shall be written 
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in a manner so as to be easily understood by customer serv-
ice employees of the Internal Revenue Service and shall pro-
vide clear instructions. 
SEC. 202. IRS FREE FILE PROGRAM. 
(a) IN GENERAL.— 
(1) The Secretary of the Treasury, or the Sec-
retary’s delegate, shall continue to operate the IRS 
Free File Program as established by the Internal Rev-
enue Service and published in the Federal Register on 
November 4, 2002 (67 Fed. Reg. 67247), including 
any subsequent agreements and governing rules estab-
lished pursuant thereto. 
(2) The IRS Free File Program shall continue to 
provide free commercial-type online individual in-
come tax preparation and electronic filing services to 
the lowest 70 percent of taxpayers by adjusted gross 
income. The number of taxpayers eligible to receive 
such services each year shall be calculated by the In-
ternal Revenue Service annually based on prior year 
aggregate taxpayer adjusted gross income data. 
(3) In addition to the services described in para-
graph (2), and in the same manner, the IRS Free 
File Program shall continue to make available to all 
taxpayers (without regard to income) a basic, online 
electronic fillable forms utility. 
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(4) The IRS Free File Program shall continue to 
work cooperatively with the private sector to provide 
the free individual income tax preparation and the 
electronic filing services described in paragraphs (2) 
and (3). 
(5) The IRS Free File Program shall work coop-
eratively with State government agencies to enhance 
and expand the use of the program to provide needed 
benefits to the taxpayer while reducing the cost of 
processing returns. 
(b) INNOVATIONS.—The Secretary of the Treasury, or 
the Secretary’s delegate, shall work with the private sector 
through the IRS Free File Program to identify and imple-
ment, consistent with applicable law, innovative new pro-
gram features to improve and simplify the taxpayer’s expe-
rience with completing and filing individual income tax re-
turns through voluntary compliance. 
SEC. 203. LOW-INCOME EXCEPTION FOR PAYMENTS OTHER-
WISE REQUIRED IN CONNECTION WITH A 
SUBMISSION OF AN OFFER-IN-COMPROMISE. 
(a) IN GENERAL.—Section 7122(c) is amended by add-
ing at the end the following new paragraph: 
‘‘(3) 
EXCEPTION
FOR
LOW-INCOME
TAX-
PAYERS.—Paragraph (1), and any user fee otherwise 
required in connection with the submission of an 
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offer-in-compromise, shall not apply to any offer-in- 
compromise with respect to a taxpayer who is an in-
dividual with adjusted gross income, as determined 
for the most recent taxable year for which such infor-
mation is available, which does not exceed 250 per-
cent of the applicable poverty level (as determined by 
the Secretary).’’. 
(b) EFFECTIVE DATE.—The amendment made by this 
section shall apply to offers-in-compromise submitted after 
the date of the enactment of this Act. 
TITLE III—SENSIBLE 
ENFORCEMENT 
SEC. 301. INTERNAL REVENUE SERVICE SEIZURE REQUIRE-
MENTS WITH RESPECT TO STRUCTURING 
TRANSACTIONS. 
Section 5317(c)(2) of title 31, United States Code, is 
amended— 
(1) by striking ‘‘Any property’’ and inserting the 
following: 
‘‘(A) IN GENERAL.—Any property’’; and 
(2) by adding at the end the following: 
‘‘(B) INTERNAL REVENUE SERVICE SEIZURE 
REQUIREMENTS WITH RESPECT TO STRUCTURING 
TRANSACTIONS.— 
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‘‘(i) PROPERTY DERIVED FROM AN IL-
LEGAL
SOURCE.—Property may only be 
seized by the Internal Revenue Service pur-
suant to subparagraph (A) by reason of a 
claimed violation of section 5324 if the 
property to be seized was derived from an 
illegal source or the funds were structured 
for the purpose of concealing the violation of 
a criminal law or regulation other than sec-
tion 5324. 
‘‘(ii) NOTICE.—Not later than 30 days 
after property is seized by the Internal Rev-
enue Service pursuant to subparagraph (A), 
the Internal Revenue Service shall— 
‘‘(I) make a good faith effort to 
find all persons with an ownership in-
terest in such property; and 
‘‘(II) provide each such person 
with a notice of the seizure and of the 
person’s rights under clause (iv). 
‘‘(iii) EXTENSION OF NOTICE UNDER 
CERTAIN
CIRCUMSTANCES.—The Internal 
Revenue Service may apply to a court of 
competent jurisdiction for one 30-day exten-
sion of the notice requirement under clause 
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(ii) if the Internal Revenue Service can es-
tablish probable cause of an imminent 
threat to national security or personal safe-
ty necessitating such extension. 
‘‘(iv) POST-SEIZURE
HEARING.—If a 
person with a property interest in property 
seized pursuant to subparagraph (A) by the 
Internal Revenue Service requests a hearing 
by a court of competent jurisdiction within 
30 days after the date on which notice is 
provided under subclause (ii), such property 
shall be returned unless the court holds an 
adversarial hearing and finds within 30 
days of such request (or such longer period 
as the court may provide, but only on re-
quest of an interested party) that there is 
probable cause to believe that there is a vio-
lation of section 5324 involving such prop-
erty and probable cause to believe that the 
property to be seized was derived from an 
illegal source or the funds were structured 
for the purpose of concealing the violation of 
a criminal law or regulation other than sec-
tion 5324.’’. 
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SEC. 302. EXCLUSION OF INTEREST RECEIVED IN ACTION 
TO RECOVER PROPERTY SEIZED BY THE IN-
TERNAL 
REVENUE 
SERVICE 
BASED 
ON 
STRUCTURING TRANSACTION. 
(a) IN GENERAL.—Part III of subchapter B of chapter 
1 is amended by inserting before section 140 the following 
new section: 
‘‘SEC. 139G. INTEREST RECEIVED IN ACTION TO RECOVER 
PROPERTY SEIZED BY THE INTERNAL REV-
ENUE SERVICE BASED ON STRUCTURING 
TRANSACTION. 
‘‘Gross income shall not include any interest received 
from the Federal Government in connection with an action 
to recover property seized by the Internal Revenue Service 
pursuant to section 5317(c)(2) of title 31, United States 
Code, by reason of a claimed violation of section 5324 of 
such title.’’. 
(b) CLERICAL AMENDMENT.—The table of sections for 
part III of subchapter B of chapter 1 is amended by insert-
ing before the item relating to section 140 the following new 
item: 
‘‘Sec. 139G. Interest received in action to recover property seized by the Internal 
Revenue Service based on structuring transaction.’’. 
(c) EFFECTIVE DATE.—The amendments made by this 
section shall apply to interest received on or after the date 
of the enactment of this Act. 
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SEC. 303. CLARIFICATION OF EQUITABLE RELIEF FROM 
JOINT LIABILITY. 
(a) IN GENERAL.—Section 6015 is amended— 
(1) in subsection (e), by adding at the end the 
following new paragraph: 
‘‘(7) 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 follows: 
‘‘(f) EQUITABLE RELIEF.— 
‘‘(1) IN GENERAL.—Under procedures prescribed 
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. 
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‘‘(2) LIMITATION.—A request for equitable relief 
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 in-
dividual could submit a timely claim for refund 
or credit of such payment.’’. 
(b) EFFECTIVE DATE.—The amendments made by this 
section shall apply to petitions or requests filed or pending 
on or after the date of the enactment of this Act. 
SEC. 304. MODIFICATION OF PROCEDURES FOR ISSUANCE 
OF THIRD-PARTY SUMMONS. 
(a) IN GENERAL.—Section 7609(f) is amended by add-
ing at the end the following flush sentence: 
‘‘The Secretary shall not issue any summons described in 
the preceding sentence unless the information sought to be 
obtained is narrowly tailored to information that pertains 
to the failure (or potential failure) of the person or group 
or class of persons referred to in paragraph (2) to comply 
with one or more provisions of the internal revenue law 
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which have been identified for purposes of such para-
graph.’’. 
(b) EFFECTIVE DATE.—The amendments made by this 
section shall apply to summonses served after the date of 
the enactment of this Act. 
SEC. 305. ESTABLISHMENT OF INCOME THRESHOLD FOR 
REFERRAL TO PRIVATE DEBT COLLECTION. 
(a) IN GENERAL.—Section 6306(d)(3) is amended by 
striking ‘‘or’’ at the end of subparagraph (C), by adding 
‘‘or’’ at the end of subparagraph (D), and by inserting after 
subparagraph (D) the following new subparagraph: 
‘‘(E) in the case of a tax receivable which 
is identified by the Secretary (or the Secretary’s 
delegate) during the period beginning on the date 
which is 180 days after the date of the enactment 
of this Act and ending on December 31, 2019, a 
taxpayer who is an individual with adjusted 
gross income, as determined for the most recent 
taxable year for which such information is avail-
able, which does not exceed 250 percent of the 
applicable poverty level (as determined by the 
Secretary),’’. 
(b) EFFECTIVE DATE.—The amendments made by this 
section shall apply to tax receivables identified by the Sec-
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retary (or the Secretary’s delegate) after the date which is 
180 days after the date of the enactment of this Act. 
SEC. 306. REFORM OF NOTICE OF CONTACT OF THIRD PAR-
TIES. 
(a) IN GENERAL.—Section 7602(c)(1) is amended to 
read as follows: 
‘‘(1) GENERAL NOTICE.—An officer or employee 
of the Internal Revenue Service may not contact any 
person other than the taxpayer with respect to the de-
termination or collection of the tax liability of such 
taxpayer unless such contact occurs during a period 
(not greater than 1 year) which is specified in a no-
tice which— 
‘‘(A) informs the taxpayer that contacts 
with persons other than the taxpayer are in-
tended to be made during such period, and 
‘‘(B) except as otherwise provided by the 
Secretary, is provided to the taxpayer not later 
than 45 days before the beginning of such period. 
Nothing in the preceding sentence shall prevent the 
issuance of notices to the same taxpayer with respect 
to the same tax liability with periods specified therein 
that, in the aggregate, exceed 1 year. A notice shall 
not be issued under this paragraph unless there is an 
intent at the time such notice is issued to contact per-
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sons other than the taxpayer during the period speci-
fied in such notice. The preceding sentence shall not 
prevent the issuance of a notice if the requirement of 
such sentence is met on the basis of the assumption 
that the information sought to be obtained by such 
contact will not be obtained by other means before 
such contact.’’. 
(b) EFFECTIVE DATE.—The amendment made by this 
section shall apply to notices provided, and contacts of per-
sons made, after the date which is 45 days after the date 
of the enactment of this Act. 
SEC. 307. MODIFICATION OF AUTHORITY TO ISSUE DES-
IGNATED SUMMONS. 
(a) IN GENERAL.—Clause (i) of section 6503(j)(2)(A) 
is amended to read as follows: 
‘‘(i) the issuance of such summons is 
preceded by a review and written approval 
of such issuance by the Administrator of the 
relevant operating division of the Internal 
Revenue Service and the Chief Counsel 
which— 
‘‘(I) states facts clearly estab-
lishing that the Secretary has made 
reasonable requests for the information 
that is the subject of the summons, and 
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‘‘(II) is attached to such sum-
mons,’’. 
(b) ESTABLISHMENT THAT REASONABLE REQUESTS 
FOR INFORMATION WERE MADE.—Subsection (j) of section 
6503 is amended by adding at the end the following new 
paragraph: 
‘‘(4) ESTABLISHMENT
THAT
REASONABLE
RE-
QUESTS
FOR
INFORMATION
WERE
MADE.—In any 
court proceeding described in paragraph (3), the Sec-
retary shall establish that reasonable requests were 
made for the information that is the subject of the 
summons.’’. 
(c) EFFECTIVE DATE.—The amendments made by this 
section shall apply to summonses issued after the date of 
the enactment of this Act. 
SEC. 308. LIMITATION ON ACCESS OF NON-INTERNAL REV-
ENUE SERVICE EMPLOYEES TO RETURNS AND 
RETURN INFORMATION. 
(a) IN GENERAL.—Section 7602 is amended by adding 
at the end the following new subsection: 
‘‘(f) LIMITATION
ON ACCESS
OF PERSONS OTHER 
THAN INTERNAL REVENUE SERVICE OFFICERS AND EM-
PLOYEES.—The Secretary shall not, under the authority of 
section 6103(n), provide any books, papers, records, or other 
data obtained pursuant to this section to any person au-
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thorized under section 6103(n), except when such person re-
quires such information for the sole purpose of providing 
expert evaluation and assistance to the Internal Revenue 
Service. No person other than an officer or employee of the 
Internal Revenue Service or the Office of Chief Counsel 
may, on behalf of the Secretary, question a witness under 
oath whose testimony was obtained pursuant to this sec-
tion.’’. 
(b) EFFECTIVE DATE.— 
(1) IN GENERAL.—Except as provided in para-
graph (2), the amendment made by this section shall 
take effect on the date of the enactment of this Act. 
(2) APPLICATION TO CONTRACTS IN EFFECT.— 
The amendment made by this section shall apply to 
any contract in effect under section 6103(n) of the In-
ternal Revenue Code of 1986, pursuant to temporary 
Treasury Regulation section 301.7602–1T proposed in 
Internal Revenue Bulletin 2014–28, Treasury Regula-
tion section 301.7602–1(b)(3), or any similar or suc-
cessor regulation, that is in effect on the date of the 
enactment of this Act. 
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TITLE IV—ORGANIZATIONAL 
MODERNIZATION 
SEC. 401. MODIFICATION OF TITLE OF COMMISSIONER OF 
INTERNAL REVENUE AND RELATED OFFI-
CIALS. 
(a) IN GENERAL.—Section 7803(a)(1)(A) is amended 
by striking ‘‘Commissioner of Internal Revenue’’ and in-
serting ‘‘Administrator of the Internal Revenue Service’’. 
(b) CONFORMING AMENDMENTS RELATED TO SECTION 
7803.— 
(1) Subsections (a)(1)(B), (a)(1)(C), (b)(3), 
(c)(1)(B)(i), and (c)(1)(B)(ii) of section 7803 are each 
amended by striking ‘‘Commissioner of Internal Rev-
enue’’ and inserting ‘‘Administrator of the Internal 
Revenue Service’’. 
(2) Section 7803(b)(2)(A) is amended by striking 
‘‘Commissioner’s’’ and inserting ‘‘Administrator’s’’. 
(3) Subsections (a)(1)(D), (a)(1)(E), (a)(2), 
(a)(3), 
(a)(4), 
(b)(2)(A), 
(b)(2)(D), 
(b)(3), 
(c)(2)(B)(iii), (c)(2)(C)(iv), and (c)(3) of section 
7803, as amended by the preceding paragraphs of this 
subsection, are amended by striking ‘‘Commissioner’’ 
each place it appears therein and inserting ‘‘Admin-
istrator’’. 
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(4) The heading of section 7803 is amended by 
striking ‘‘COMMISSIONER
OF
INTERNAL
REV-
ENUE’’ and inserting ‘‘ADMINISTRATOR OF THE 
INTERNAL REVENUE SERVICE’’. 
(5) The heading of section 7803(a) is amended 
by striking ‘‘COMMISSIONER OF INTERNAL REVENUE’’ 
and inserting ‘‘ADMINISTRATOR OF THE INTERNAL 
REVENUE SERVICE’’. 
(6) The heading of section 7803(c)(3) is amended 
by striking ‘‘COMMISSIONER’’ and inserting ‘‘ADMIN-
ISTRATOR’’. 
(7) The table of sections for subchapter A of 
chapter 80 is amended by striking the item relating 
to section 7803 and inserting the following new item: 
‘‘Sec. 7803. Administrator of the Internal Revenue Service; other officials.’’. 
(c) OTHER CONFORMING AMENDMENTS TO THE IN-
TERNAL REVENUE CODE OF 1986.— 
(1) Section 6307(c) is amended by striking 
‘‘Commissioner of Internal Revenue’’ and inserting 
‘‘Administrator of the Internal Revenue Service’’. 
(2) Section 6673(a)(2)(B) is amended by strik-
ing ‘‘Commissioner of Internal Revenue’’ and insert-
ing ‘‘Administrator of the Internal Revenue Service’’. 
(3) Section 6707(c) is amended by striking 
‘‘Commissioner’’ and inserting ‘‘Administrator’’. 
(4) Section 6707A(d) is amended— 
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(A) in paragraph (1), by striking ‘‘Commis-
sioner of Internal Revenue’’ and inserting ‘‘Ad-
ministrator of the Internal Revenue Service’’, 
and 
(B) in paragraph (3), by striking ‘‘Commis-
sioner’’ each place it appears and inserting ‘‘Ad-
ministrator’’. 
(5)(A) Subsections (a) and (g) of section 7345 
are each amended by striking ‘‘Commissioner of In-
ternal Revenue’’ and inserting ‘‘Administrator of the 
Internal Revenue Service’’. 
(B) Section 7345(g) is amended— 
(i) by striking ‘‘Deputy Commissioner for 
Services and Enforcement’’ and inserting ‘‘Dep-
uty Administrator for Services and Enforce-
ment’’, and 
(ii) by striking ‘‘Commissioner of an oper-
ating division’’ and inserting ‘‘Administrator of 
an operating division’’. 
(C) Subsections (c)(1), (d) and (e)(1) of section 
7345 are each amended by striking ‘‘Commissioner’’ 
each place it appears therein and inserting ‘‘Admin-
istrator’’. 
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erwise, means the Administrator of the Internal Rev-
enue Service.’’. 
(11)(A) Section 7804(a) is amended by striking 
‘‘Commissioner of Internal Revenue’’ and inserting 
‘‘Administrator of the Internal Revenue Service’’. 
(B) Subsections (a), (b)(1), and (b)(2) of section 
7804(a), as amended by subparagraph (A), are each 
amended by striking ‘‘Commissioner’’ each place it 
appears therein and inserting ‘‘Administrator’’. 
(12) Section 7811(c)(1) is amended by striking 
‘‘the Commissioner of Internal Revenue, or the Dep-
uty Commissioner of Internal Revenue’’ and inserting 
‘‘the Administrator of the Internal Revenue Service, 
or the Deputy Commissioner of the Internal Revenue 
Service’’. 
(d) AMENDMENTS TO SECTION 8D OF THE INSPECTOR 
GENERAL ACT OF 1978.— 
(1) Subsections (g)(2), (k)(1)(C), (l)(1), and 
(l)(2)(A) of section 8D of the Inspector General Act 
of 1978 are each amended by striking ‘‘Commissioner 
of Internal Revenue’’ and inserting ‘‘Administrator of 
the Internal Revenue Service’’. 
(2) Section 8D(l)(2)(B) of such Act is amended 
by striking ‘‘Commissioner’’ each place it appears 
therein and inserting ‘‘Administrator’’. 
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(e) OTHER REFERENCES.—Any reference in any pro-
vision of law, or regulation or other guidance, to the Com-
missioner of Internal Revenue, or to any Deputy or Assist-
ant Commissioner of Internal Revenue, or to a Commis-
sioner of any division or region of the Internal Revenue 
Service, shall be treated as a reference to the Administrator 
of the Internal Revenue Service, or to the appropriate Dep-
uty or Assistant Administrator of the Internal Revenue 
Service, or to the appropriate Administrator of such divi-
sion or region, respectively. 
(f) CONTINUITY.—In the case of any individual ap-
pointed by the President, by and with the advice and con-
sent of the Senate, as Commissioner of Internal Revenue 
under section 7803(a)(1)(A) of the Internal Revenue Code 
of 1986, and serving in such position immediately before 
the date of the enactment of this Act, the amendments made 
by this section shall be construed as changing the title of 
such individual and shall not be construed to— 
(1) require the reappoint of such individual 
under such section, or 
(2) alter the remaining term of such person 
under section 7803(a)(1)(B). 
SEC. 402. OFFICE OF THE NATIONAL TAXPAYER ADVOCATE. 
(a) TAXPAYER ADVOCATE DIRECTIVES.— 
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(1) IN GENERAL.—Section 7803(c) is amended 
by adding at the end the following new paragraph: 
‘‘(5) TAXPAYER ADVOCATE DIRECTIVES.—In the 
case of any Taxpayer Advocate Directive issued by 
the National Taxpayer Advocate pursuant to a dele-
gation of authority from the Administrator of the In-
ternal Revenue Service— 
‘‘(A) the Administrator or a Deputy Ad-
ministrator shall modify, rescind, or ensure com-
pliance with such directive not later than 90 
days after the issuance of such directive, and 
‘‘(B) in the case of any directive which is 
modified or rescinded by a Deputy Adminis-
trator, the National Taxpayer Advocate may 
(not later than 90 days after such modification 
or rescission) appeal to the Administrator and 
the Administrator shall (not later than 90 days 
after such appeal is made) ensure compliance 
with such directive as issued by the National 
Taxpayer Advocate or provide the National Tax-
payer Advocate with a detailed description of the 
reasons for any modification or rescission made 
or upheld by the Administrator pursuant to such 
appeal.’’. 
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(2) REPORT TO CERTAIN COMMITTEES OF CON-
GRESS
REGARDING
DIRECTIVES.—Section 
7803(c)(2)(B)(ii) is amended by redesignating sub-
clauses (VIII) through (XI) as subclauses (IX) through 
(XII), respectively, and by inserting after subclause 
(VII) the following new subclause: 
‘‘(VIII) identify any Taxpayer 
Advocate Directive which was not hon-
ored by the Internal Revenue Service 
in a timely manner, as specified under 
paragraph (5);’’. 
(b) NATIONAL TAXPAYER ADVOCATE ANNUAL RE-
PORTS TO CONGRESS.— 
(1) INCLUSION
OF
MOST
SERIOUS
TAXPAYER 
PROBLEMS.—Section 7803(c)(2)(B)(ii)(III) is amend-
ed by striking ‘‘at least 20’’ and inserting ‘‘the 10’’. 
(2) COORDINATION WITH TREASURY INSPECTOR 
GENERAL
FOR
TAX
ADMINISTRATION.—Section 
7803(c)(2) is amended by adding at the end the fol-
lowing new subparagraph: . 
‘‘(E) COORDINATION
WITH
TREASURY
IN-
SPECTOR GENERAL FOR TAX ADMINISTRATION.— 
Before beginning any research or study, the Na-
tional Taxpayer Advocate shall coordinate with 
the Treasury Inspector General for Tax Admin-
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istration to ensure that the National Taxpayer 
Advocate does not duplicate any action that the 
Treasury Inspector General for Tax Administra-
tion has already undertaken or has a plan to un-
dertake.’’. 
(3) STATISTICAL SUPPORT.— 
(A) IN GENERAL.—Section 6108 is amended 
by adding at the end the following new sub-
section: 
‘‘(d) STATISTICAL SUPPORT FOR NATIONAL TAXPAYER 
ADVOCATE.—The Secretary shall, upon request of the Na-
tional Taxpayer Advocate, provide the National Taxpayer 
Advocate with statistical support in connection with the 
preparation by the National Taxpayer Advocate of the an-
nual report described in section 7803(c)(2)(B)(ii). Such sta-
tistical support shall include statistical studies, compila-
tions, and the review of information provided by the Na-
tional Taxpayer Advocate for statistical validity and sound 
statistical methodology.’’. 
(B) 
DISCLOSURE
OF
REVIEW.—Section 
7803(c)(2)(B)(ii), as amended by subsection (a), 
is amended by redesignating subclause (XII) as 
subclause (XIII) and by inserting after subclause 
(XI) the following new subclause: 
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‘‘(XII) with respect to any statis-
tical information included in such re-
port, include a statement of whether 
such statistical information was re-
viewed or provided by the Secretary 
under section 6108(d) and, if so, 
whether the Secretary determined such 
information to be statistically valid 
and based on sound statistical method-
ology.’’. 
(C) 
CONFORMING
AMENDMENT.—Section 
7803(c)(2)(B)(iii) is amended by adding at the 
end the following: ‘‘The preceding sentence shall 
not apply with respect to statistical information 
provided to the Secretary for review, or received 
from the Secretary, under section 6108(d).’’. 
(c) SALARY OF NATIONAL TAXPAYER ADVOCATE.—Sec-
tion 7803(c)(1)(B)(i) is amended by striking ‘‘, or, if the 
Secretary of the Treasury so determines, at a rate fixed 
under section 9503 of such title’’. 
(d) EFFECTIVE DATE.— 
(1) IN GENERAL.—Except as otherwise provided 
in this subsection, the amendments made by this sec-
tion shall take effect on the date of the enactment of 
this Act. 
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(2) SALARY
OF
NATIONAL
TAXPAYER
ADVO-
CATE.—The amendment made by subsection (c) shall 
apply to compensation paid to individuals appointed 
as the National Taxpayer Advocate after the date of 
the enactment of this Act. 
SEC. 403. ELIMINATION OF IRS OVERSIGHT BOARD. 
(a) IN GENERAL.—Subchapter A of chapter 80 is 
amended by striking section 7802 (and by striking the item 
relating to such section in the table of sections of such sub-
chapter). 
(b) CONFORMING AMENDMENTS.— 
(1) Section 4946(c) is amended by adding ‘‘or’’ 
at the end of paragraph (5), by striking ‘‘, or’’ at the 
end of paragraph (6) and inserting a period, and by 
striking paragraph (7). 
(2) Section 6103(h) is amended by striking 
paragraph (6). 
(3) Section 7803(a) is amended by striking 
paragraph (4). 
(4) Section 7803(c)(1)(B)(ii) is amended by 
striking ‘‘and the Oversight Board’’. 
(5) Section 7803(c)(2)(B)(iii) is amended by 
striking ‘‘the Oversight Board,’’. 
(6) Section 8D of the Inspector General Act of 
1978 is amended— 
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(A) in subsections (g)(2) and (h), by strik-
ing ‘‘the Internal Revenue Service Oversight 
Board and’’, 
(B) in subsection (l)(1), by striking ‘‘or the 
Internal Revenue Service Oversight Board’’, and 
(C) in subsection (l)(2), by striking ‘‘and 
the Internal Revenue Service Oversight Board’’. 
SEC. 404. MODERNIZATION OF INTERNAL REVENUE SERV-
ICE ORGANIZATIONAL STRUCTURE. 
(a) IN GENERAL.—Not later than September 30, 2020, 
the Administrator of the Internal Revenue Service shall sub-
mit to Congress a comprehensive written plan to redesign 
the organization of the Internal Revenue Service. Such plan 
shall— 
(1) ensure the successful implementation of the 
priorities specified by Congress in this Act, 
(2) prioritize taxpayer services to ensure that all 
taxpayers easily and readily receive the assistance 
that they need, 
(3) streamline the structure of the agency includ-
ing minimizing the duplication of services and re-
sponsibilities within the agency, 
(4) best position the Internal Revenue Service to 
combat cybersecurity and other threats to the Internal 
Revenue Service, and 
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(5) address whether the Criminal Investigation 
Division of the Internal Revenue Service should re-
port directly to the Administrator. 
(b) REPEAL OF RESTRICTION ON ORGANIZATIONAL 
STRUCTURE
OF INTERNAL REVENUE SERVICE.—Para-
graph (3) of section 1001(a) of the Internal Revenue Service 
Restructuring and Reform Act of 1998 shall cease to apply 
beginning 1 year after the date on which the Administrator 
of the Internal Revenue Service submits to Congress the 
plan described in subsection (a). 
TITLE V—TAX COURT 
SEC. 501. DISQUALIFICATION OF JUDGE OR MAGISTRATE 
JUDGE OF THE TAX COURT. 
(a) IN GENERAL.—Part II of subchapter C of chapter 
76 is amended by adding at the end the following new sec-
tion: 
‘‘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 following 
new item: 
‘‘Sec. 7467. Disqualification of judge or magistrate judge of the Tax Court.’’. 
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SEC. 502. OPINIONS AND JUDGMENTS. 
(a) IN GENERAL.—Section 7459 is amended by strik-
ing all the 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 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) CONFORMING AMENDMENTS TO SECTION 7459.— 
(1) Subsections (c), (d), (e), and (f) of section 
7459 are each amended by striking ‘‘decision’’ each 
place it appears and inserting ‘‘judgment’’. 
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(2) The headings of subsections (c), (d), and (e) 
of section 7459 are each amended by striking ‘‘DECI-
SION’’ and inserting ‘‘JUDGMENT’’. 
(3) 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.’’. 
(c) OTHER CONFORMING AMENDMENTS.— 
(1) The following provisions are each amended 
by striking ‘‘decision’’ and inserting ‘‘judgment’’: 
(A) Section 1313(a)(1). 
(B) Section 6213(a). 
(C) Section 6214(d). 
(D) Section 6225(a)(2). 
(E) Section 6226(g). 
(F) Section 6228(a)(6). 
(G) Subsections (a)(3)(B) and (c)(1)(A)(ii) 
of section 6230. 
(H) Section 6247(d). 
(I) Section 6252(e). 
(J) Section 6404(h)(2)(C). 
(K) Section 6503(a)(1). 
(L) Section 6673(a)(1)(C). 
(M) Subsections (c), (f), and (g) of section 
6861. 
(N) Section 6863(b)(3)(C). 
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(O) Section 7428(a). 
(P) Section 7428(c)(1)(C)(i). 
(Q) Section 7430(f)(3). 
(R) Section 7436(c)(2). 
(S) Section 7461(b)(2). 
(T) Subsections (a)(4), (b), and (d) of sec-
tion 7463. 
(U) Subsections (a)(2)(B) and (b)(4) of sec-
tion 7476. 
(V) Section 7477(a). 
(W) Section 7478(a)(2). 
(X) Subsections (a)(2) and (c) of section 
7479. 
(2) The following provisions are each amended 
by striking ‘‘decision’’ each place it appears and in-
serting ‘‘judgment’’: 
(A) Subsections (a) and (b)(3) of section 
6215. 
(B) Section 6226(h). 
(C) Section 6247(e). 
(D) Subsections (d) and (e) of section 6861. 
(E) Section 6863(b)(2). 
(F) Section 7422. 
(G) Subsections (a) and (b) of section 7460. 
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(H) Subsections (a), (b), (c), and (d) of sec-
tion 7463. 
(I) Section 7482. 
(J) Section 7483. 
(K) Section 7485(b). 
(L) Section 7481. 
(3) Sections 7422 and 7482 are each amended by 
striking ‘‘decisions’’ each place it appears and insert-
ing ‘‘judgments’’. 
(4) Section 7430(f)(1) is amended by striking 
‘‘decision or’’ both places it appears. 
(5) Subsections (a) and (b) of section 7460 are 
each amended by striking ‘‘report’’ each place it ap-
pears and inserting ‘‘opinion’’. 
(6) Section 7461(a) is amended— 
(A) by striking ‘‘reports’’ and inserting 
‘‘opinions’’, and 
(B) by striking ‘‘report’’ and inserting 
‘‘opinion’’. 
(7) Section 7462 is amended by striking ‘‘re-
ports’’ each place it appears and inserting ‘‘opin-
ions’’. 
(8) Section 7487(1) is amended by striking ‘‘de-
cisions’’ and inserting ‘‘judgments’’. 
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(9) The headings of sections 6214(b), 7463(b), 
7481(a), 7481(b), 7481(d), and 7485(b) are each 
amended by striking ‘‘DECISIONS’’ and inserting 
‘‘JUDGMENTS’’. 
(10) The headings of sections 6226(h), 6247(e), 
6861(c), 
6861(d), 
7443A(c), 
7481(a)(2), 
and 
7481(a)(3) are each amended by striking ‘‘DECISION’’ 
and inserting ‘‘JUDGMENT’’. 
(11) The headings of sections 6863(b)(2), 
6863(b)(3), 7430(f)(3), and 7482(a)(2)(B) are each 
amended by striking ‘‘DECISION’’ and inserting 
‘‘JUDGMENT’’. 
(12) The heading of section 7436(c)(2) is amend-
ed by striking ‘‘DECISIONS’’ and inserting ‘‘JUDG-
MENT’’. 
(13) The heading of section 7460(a) is amended 
by striking ‘‘REPORTS’’ and inserting ‘‘OPINIONS’’. 
(14) The heading of section 7462 is amended by 
striking ‘‘REPORTS’’ and inserting ‘‘OPINIONS’’. 
(15) The heading of subchapter D of chapter 76 
is amended by striking ‘‘Decisions’’ and inserting 
‘‘Judgments’’. 
(16) The heading of section 7481 is amended by 
striking ‘‘DECISION’’ and inserting ‘‘JUDGMENT’’. 
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(17) The item relating to section 7462 in the 
table of sections for part II of subchapter C of chapter 
76 is amended to read as follows: 
‘‘Sec. 7462. Publication of opinions.’’. 
(18) The item relating to subchapter D in the 
table of subchapters for chapter 76 is amended to read 
as follows: 
‘‘SUBCHAPTER D.—COURT REVIEW OF TAX COURT JUDGMENTS’’. 
(19) The item relating to section 7481 in the 
table of sections for part III of subchapter D of chap-
ter 76 is amended to read as follows: 
‘‘Sec. 7481. Date when Tax Court judgment becomes final.’’. 
(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. 503. TITLE OF SPECIAL TRIAL JUDGE CHANGED TO 
MAGISTRATE JUDGE OF THE TAX COURT. 
(a) IN GENERAL.—Section 7443A is amended— 
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(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 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), 
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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’’. 
(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’’. 
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(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’’. 
(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. 504. REPEAL OF DEADWOOD RELATED TO BOARD OF 
TAX APPEALS. 
(a) Section 7459 is amended by striking subsection (f) 
and redesignating subsection (g) as subsection (f). 
(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.’’. 
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