as a deduction under section 162 or 212(3) in connection 
with an audit of the taxpayer’s return of the tax imposed 
by this chapter for any taxable year under the National 
Research Program, but only if such audit results in no 
increase in the tax liability of the taxpayer for such taxable 
year. 
‘‘(c) DENIAL OF DOUBLE BENEFIT.—No deduction 
shall be allowed under any other provision of this chapter 
for any amount for which a deduction is allowed under 
this section.’’. 
(c) CLERICAL AMENDMENT.—The table of sections 
for part VII of subchapter B of chapter 1 of the Internal 
Revenue Code of 1986 is amended by striking the item 
relating to section 224 and by inserting after the item re-
lating to section 223 the following new items: 
‘‘Sec. 224. Expenses relating to certain audits. 
‘‘Sec. 225. Cross reference.’’. 
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to taxable years beginning after 
the date of the enactment of this Act. 
SEC. 15. TERM LIMIT FOR NATIONAL TAXPAYER ADVOCATE. 
(a) IN GENERAL.—Subparagraph (B) of section 
7803(c)(1) of the Internal Revenue Code of 1986 is 
amended by adding at the end the following new clause: 
‘‘(v) TERM.—The term of the Na-
tional Taxpayer Advocate shall be a 10- 
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year term, beginning with a term to com-
mence on the date which is 18 months 
after the date of the enactment of the 
Small Business Taxpayer Bill of Rights 
Act of 2022. Each subsequent term shall 
begin on the day after the date on which 
the previous term expires. The National 
Taxpayer Advocate may be appointed to 
serve more than 1 term.’’. 
(b) EFFECTIVE DATE.—The term of any individual 
serving as the National Taxpayer Advocate under section 
7803(c) of the Internal Revenue Code of 1986 as of the 
date of the enactment of this Act shall end as of the day 
before the date which is 18 months after such date of en-
actment, unless such individual is reappointed as the Na-
tional Taxpayer Advocate for a subsequent term pursuant 
to section 7803(c)(1)(B)(v) of such Code. 
SEC. 16. RELEASE OF IRS LEVY DUE TO ECONOMIC HARD-
SHIP FOR BUSINESS TAXPAYERS. 
(a) IN GENERAL.—Subparagraph (D) of section 
6343(a)(1) of the Internal Revenue Code of 1986 is 
amended by striking ‘‘or’’ and inserting ‘‘including the fi-
nancial condition of the taxpayer’s viable trade or busi-
ness, or’’. 
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(b) DETERMINATION
OF ECONOMIC HARDSHIP.— 
Subsection (a) of section 6343 of the Internal Revenue 
Code of 1986 is amended by adding at the end the fol-
lowing new paragraph: 
‘‘(4) DETERMINATION OF ECONOMIC HARDSHIP 
TO BUSINESS TAXPAYER.—In determining whether 
to release any levy under paragraph (1)(D), the Sec-
retary shall consider— 
‘‘(A) the economic viability of the business, 
‘‘(B) the nature and extent of the hardship 
created by the levy (including whether the tax-
payer has exercised ordinary business care and 
prudence), and 
‘‘(C) the potential harm to individuals if 
the business is liquidated.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to levies made after the date of 
the enactment of this Act. 
SEC. 17. REPEAL OF PARTIAL PAYMENT REQUIREMENT ON 
SUBMISSIONS OF OFFERS-IN-COMPROMISE. 
(a) IN GENERAL.—Section 7122 of the Internal Rev-
enue Code of 1986 is amended by striking subsection (c) 
and by redesignating subsections (d), (e), (f), and (g) as 
subsections (c), (d), (e), and (f), respectively. 
(b) CONFORMING AMENDMENTS.— 
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(1) Paragraph (3) of section 7122(c) of the In-
ternal Revenue Code of 1986, as redesignated by 
subsection (a), is amended by inserting ‘‘and’’ at the 
end of subparagraph (A), by striking ‘‘, and’’ at the 
end of subparagraph (B) and inserting a period, and 
by striking subparagraph (C). 
(2) Section 7122 of such Code, as amended by 
this section, is amended by adding at the end the 
following new subsection: 
‘‘(g) APPLICATION OF USER FEE.—In the case of 
any assessed tax or other amounts imposed under this title 
with respect to such tax which is the subject of an offer- 
in-compromise, such tax or other amounts shall be reduced 
by any user fee imposed under this title with respect to 
such offer-in-compromise.’’. 
(3) Section 6159(g) of such Code is amended 
by striking ‘‘section 7122(e)’’ and inserting ‘‘section 
7122(d)’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to offers-in-compromise submitted 
after the date of the enactment of this Act. 
Æ 
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