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-
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. 
Subtitle B—Improved Service 
SEC. 1101. COMPREHENSIVE CUSTOMER SERVICE STRAT-
EGY. 
(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 (or the Secretary’s delegate) shall 
submit to Congress a written comprehensive customer serv-
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ice strategy for the Internal Revenue 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-
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. 
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(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 (or the Sec-
retary’s delegate) shall make available the updated guidance 
and training materials described in subsection (a)(4) (in-
cluding the Internal Revenue Manual). Such updated guid-
ance and training materials (including the Internal Rev-
enue Manual) shall be written in a manner so as to be eas-
ily understood by customer service employees of the Internal 
Revenue Service and shall provide clear instructions. 
SEC. 1102. 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-
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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. 
(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. 
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SEC. 1103. LOW-INCOME EXCEPTION FOR PAYMENTS OTH-
ERWISE 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 
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. 
Subtitle C—Sensible Enforcement 
SEC. 1201. INTERNAL REVENUE SERVICE SEIZURE RE-
QUIREMENTS 
WITH 
RESPECT 
TO 
STRUC-
TURING TRANSACTIONS. 
Section 5317(c)(2) of title 31, United States Code, is 
amended— 
(1) by striking ‘‘Any property’’ and inserting the 
following: 
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‘‘(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.— 
‘‘(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 so 
found with a notice of the seizure and 
of the person’s rights under clause (iv). 
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‘‘(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 
(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 an ownership interest in prop-
erty 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 no-
tice 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 request of an interested party) that 
there is probable cause to believe that there 
is a violation of section 5324 involving such 
property and probable cause to believe that 
the property to be seized was derived from 
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an illegal source or the funds were struc-
tured for the purpose of concealing the vio-
lation of a criminal law or regulation other 
than section 5324.’’. 
SEC. 1202. 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. 139H. 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: 
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‘‘Sec. 139H. 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. 
SEC. 1203. 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 
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‘‘(B) relief is not available to such indi-
vidual under subsection (b) or (c), 
the Secretary may relieve such individual of such li-
ability. 
‘‘(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. 1204. 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 
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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 
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 that 
is 45 days after the date of the enactment of this Act. 
SEC. 1205. PRIVATE DEBT COLLECTION AND SPECIAL COM-
PLIANCE PERSONNEL PROGRAM. 
(a) CERTAIN TAX RECEIVABLES NOT ELIGIBLE FOR 
COLLECTION UNDER TAX COLLECTION CONTRACTS.—Sec-
tion 6306(d)(3) is amended by striking ‘‘or’’ at the end of 
subparagraph (C) and by inserting after subparagraph (D) 
the following new subparagraphs: 
‘‘(E) a taxpayer substantially all of whose 
income consists of disability insurance benefits 
under section 223 of the Social Security Act or 
supplemental security income benefits under title 
XVI of the Social Security Act (including sup-
plemental security income benefits of the type de-
scribed in section 1616 of such Act or section 212 
of Public Law 93–66), or 
‘‘(F) a taxpayer who is an individual with 
adjusted gross income, as determined for the 
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most recent taxable year for which such informa-
tion is available, which does not exceed 200 per-
cent of the applicable poverty level (as deter-
mined by the Secretary),’’. 
(b) DETERMINATION OF INACTIVE TAX RECEIVABLES 
ELIGIBLE FOR COLLECTION UNDER TAX COLLECTION CON-
TRACTS.—Section 6306(c)(2)(A)(ii) is amended by striking 
‘‘more than 1⁄3 of the period of the applicable statute of limi-
tation has lapsed’’ and inserting ‘‘more than 2 years has 
passed since assessment’’. 
(c) MAXIMUM LENGTH OF INSTALLMENT AGREEMENTS 
OFFERED UNDER TAX COLLECTION CONTRACTS.—Section 
6306(b)(1)(B) is amended by striking ‘‘5 years’’ and insert-
ing ‘‘7 years’’. 
(d) CLARIFICATION THAT SPECIAL COMPLIANCE PER-
SONNEL PROGRAM ACCOUNT MAY BE USED FOR PROGRAM 
COSTS.— 
(1) IN GENERAL.—Section 6307(b) is amended— 
(A) in paragraph (2), by striking all that 
follows ‘‘under such program’’ and inserting a 
period, and 
(B) in paragraph (3), by striking all that 
follows ‘‘out of such account’’ and inserting ‘‘for 
other than program costs.’’. 
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(2) COMMUNICATIONS, SOFTWARE, AND
TECH-
NOLOGY COSTS TREATED AS PROGRAM COSTS.—Sec-
tion 6307(d)(2)(B) is amended by striking ‘‘tele-
communications’’ and inserting ‘‘communications, 
software, technology’’. 
(3) 
CONFORMING
AMENDMENT.—Section 
6307(d)(2) is amended by striking ‘‘and’’ at the end 
of subparagraph (A), by striking the period at the end 
of subparagraph (B) and inserting ‘‘, and’’, and by 
inserting after subparagraph (B) the following new 
subparagraph: 
‘‘(C) reimbursement of the Internal Revenue 
Service or other government agencies for the cost 
of administering the qualified tax collection pro-
gram under section 6306.’’. 
(e) EFFECTIVE DATES.— 
(1) IN GENERAL.—Except as otherwise provided 
in this subsection, the amendments made by this sec-
tion shall apply to tax receivables identified by the 
Secretary (or the Secretary’s delegate) after December 
31, 2020. 
(2) MAXIMUM LENGTH OF INSTALLMENT AGREE-
MENTS.—The amendment made by subsection (c) 
shall apply to contracts entered into after the date of 
the enactment of this Act. 
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(3) USE OF SPECIAL COMPLIANCE PERSONNEL 
PROGRAM ACCOUNT.—The amendment made by sub-
section (d) shall apply to amounts expended from the 
special compliance personnel program account after 
the date of the enactment of this Act. 
SEC. 1206. 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 
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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-
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. 1207. MODIFICATION OF AUTHORITY TO ISSUE DES-
IGNATED SUMMONS. 
(a) IN GENERAL.—Paragraph (1) of section 6503(j) is 
amended by striking ‘‘coordinated examination program’’ 
and inserting ‘‘coordinated industry case program’’. 
(b) REQUIREMENTS FOR SUMMONS.—Clause (i) of sec-
tion 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 Commissioner of the 
relevant operating division of the Internal 
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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 
‘‘(II) is attached to such sum-
mons,’’. 
(c) 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.’’. 
(d) EFFECTIVE DATE.—The amendments made by this 
section shall apply to summonses issued after the date which 
is 45 days after the date of the enactment of this Act. 
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