I 
119TH CONGRESS 
1ST SESSION H. R. 2782 
To provide a taxpayer bill of rights for small businesses. 
IN THE HOUSE OF REPRESENTATIVES 
APRIL 9, 2025 
Mr. KUSTOFF introduced the following bill; which was referred to the Com-
mittee on Ways and Means, and in addition to the Committee on Over-
sight and Government Reform, for a period to be subsequently deter-
mined by the Speaker, in each case for consideration of such provisions 
as fall within the jurisdiction of the committee concerned 
A BILL 
To provide a taxpayer bill of rights for small businesses. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE; TABLE OF CONTENTS. 
(a) SHORT TITLE.—This Act may be cited as the 
‘‘Small Business Taxpayer Bill of Rights Act of 2025’’. 
(b) TABLE OF CONTENTS.—The table of contents of 
this Act is as follows: 
Sec. 1. Short title; table of contents. 
Sec. 2. Modification of standards for awarding of costs and certain fees. 
Sec. 3. Civil damages allowed for reckless or intentional disregard of internal 
revenue laws. 
Sec. 4. Modifications relating to certain offenses by officers and employees in 
connection with revenue laws. 
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Sec. 5. Modifications relating to civil damages for unauthorized inspection or 
disclosure of returns and return information. 
Sec. 6. Ban on ex parte discussions. 
Sec. 7. Right to independent conference. 
Sec. 8. Alternative dispute resolution procedures. 
Sec. 9. Increase in monetary penalties for certain unauthorized disclosures of 
information. 
Sec. 10. Ban on raising new issues on appeal. 
Sec. 11. Limitation on enforcement of liens against principal residences. 
Sec. 12. Additional provisions relating to mandatory termination for mis-
conduct. 
Sec. 13. Review by the Treasury Inspector General for Tax Administration. 
Sec. 14. Deduction for expenses relating to certain audits. 
Sec. 15. Term limit for National Taxpayer Advocate. 
Sec. 16. Release of IRS levy due to economic hardship for business taxpayers. 
Sec. 17. Repeal of partial payment requirement on submissions of offers-in- 
compromise. 
SEC. 2. MODIFICATION OF STANDARDS FOR AWARDING OF 
COSTS AND CERTAIN FEES. 
(a) SMALL BUSINESSES ELIGIBLE WITHOUT RE-
GARD TO NET WORTH.—Subparagraph (D) of section 
7430(c)(4) of the Internal Revenue Code of 1986 is 
amended by striking ‘‘and’’ at the end of clause (i)(II), 
by striking the period at the end of clause (ii) and insert-
ing ‘‘, and’’, and by adding at the end the following new 
clause: 
‘‘(iii) in the case of an eligible small 
business, the net worth limitation in clause 
(ii) of such section shall not apply.’’. 
(b) ELIGIBLE SMALL BUSINESS.—Paragraph (4) of 
section 7430(c) of the Internal Revenue Code of 1986 is 
amended by adding at the end the following new subpara-
graph: 
‘‘(F) ELIGIBLE SMALL BUSINESS.— 
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for such calendar year, determined by 
substituting ‘calendar year 2024’ for 
‘calendar year 2016’ in subparagraph 
(A)(ii) thereof. 
If any amount as increased under the pre-
ceding sentence is not a multiple of $500, 
such amount shall be rounded to the next 
lowest multiple of $500.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to proceedings commenced after 
the date of the enactment of this Act. 
SEC. 3. CIVIL DAMAGES ALLOWED FOR RECKLESS OR IN-
TENTIONAL DISREGARD OF INTERNAL REV-
ENUE LAWS. 
(a) INCREASE IN AMOUNT OF DAMAGES.— 
(1) IN GENERAL.—Section 7433(b) of the In-
ternal Revenue Code of 1986 is amended by striking 
‘‘$1,000,000 ($100,000, in the case of negligence)’’ 
and inserting ‘‘$5,000,000 ($500,000, in the case of 
negligence)’’. 
(2) ADJUSTMENT
FOR
INFLATION.—Section 
7433 of such Code is amended by adding at the end 
the following new subsection: 
‘‘(f) ADJUSTMENT FOR INFLATION.—In the case of 
any calendar year after 2025, the $5,000,000 and 
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$500,000 amounts in subsection (b) shall each be in-
creased by an amount equal to— 
‘‘(1) such dollar amount, multiplied by 
‘‘(2) the cost-of-living adjustment determined 
under section 1(f)(3) for such calendar year, deter-
mined by substituting ‘calendar year 2023’ for ‘cal-
endar year 2016’ in subparagraph (A)(ii) thereof. 
If any amount as increased under the preceding sentence 
is not a multiple of $500, such amount shall be rounded 
to the next lowest multiple of $500.’’. 
(b) EXTENSION OF TIME TO BRING ACTION.—Sec-
tion 7433(d)(3) of the Internal Revenue Code of 1986 is 
amended by striking ‘‘2 years’’ and inserting ‘‘5 years’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to actions of employees of the In-
ternal Revenue Service after the date of the enactment 
of this Act. 
SEC. 4. MODIFICATIONS RELATING TO CERTAIN OFFENSES 
BY OFFICERS AND EMPLOYEES IN CONNEC-
TION WITH REVENUE LAWS. 
(a) INCREASE IN PENALTY.—Section 7214 of the In-
ternal Revenue Code of 1986 is amended— 
(1) by striking ‘‘$10,000’’ in subsection (a) and 
inserting ‘‘$25,000’’, and 
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(2) by striking ‘‘$5,000’’ in subsection (b) and 
inserting ‘‘$10,000’’. 
(b) ADJUSTMENT FOR INFLATION.—Section 7214 of 
the Internal Revenue Code of 1986, as amended by sub-
section (a), is amended by redesignating subsection (c) as 
subsection (d) and by inserting after subsection (b) the 
following new subsection: 
‘‘(c) ADJUSTMENT FOR INFLATION.—In the case of 
any calendar year after 2025, the $25,000 amount in sub-
section (a) and the $10,000 amount in subsection (b) shall 
each be increased by an amount equal to— 
‘‘(1) such dollar amount, multiplied by 
‘‘(2) the cost-of-living adjustment determined 
under section 1(f)(3) for such calendar year, deter-
mined by substituting ‘calendar year 2024’ for ‘cal-
endar year 2016’ in subparagraph (A)(ii) thereof. 
If any amount as increased under the preceding sentence 
is not a multiple of $100, such amount shall be rounded 
to the next lowest multiple of $100.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall take effect on the date of the enactment 
of this Act. 
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SEC. 5. MODIFICATIONS RELATING TO CIVIL DAMAGES FOR 
UNAUTHORIZED 
INSPECTION 
OR 
DISCLO-
SURE OF RETURNS AND RETURN INFORMA-
TION. 
(a) INCREASE IN AMOUNT OF DAMAGES.—Subpara-
graph (A) of section 7431(c)(1) of the Internal Revenue 
Code of 1986 is amended by striking ‘‘$1,000’’ and insert-
ing ‘‘$10,000’’. 
(b) ADJUSTMENT FOR INFLATION.—Section 7431 of 
the Internal Revenue Code of 1986 is amended by adding 
at the end the following new subsection: 
‘‘(i) ADJUSTMENT FOR INFLATION.—In the case of 
any calendar year after 2025, the $10,000 amount in sub-
section (c)(1)(A) shall be increased by an amount equal 
to— 
‘‘(1) such dollar amount, multiplied by 
‘‘(2) the cost-of-living adjustment determined 
under section 1(f)(3) for such calendar year, deter-
mined by substituting ‘calendar year 2024’ for ‘cal-
endar year 2016’ in subparagraph (A)(ii) thereof. 
If any amount as increased under the preceding sentence 
is not a multiple of $100, such amount shall be rounded 
to the next lowest multiple of $100.’’. 
(c) PERIOD FOR BRINGING ACTION.—Subsection (d) 
of section 7431 of the Internal Revenue Code of 1986 is 
amended by striking ‘‘2 years’’ and inserting ‘‘5 years’’. 
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(d) EFFECTIVE DATE.—The amendment made by 
this section shall apply to inspections and disclosure occur-
ring on and after the date of the enactment of this Act. 
SEC. 6. BAN ON EX PARTE DISCUSSIONS. 
(a) 
IN
GENERAL.—Notwithstanding 
section 
1001(a)(4) of the Internal Revenue Service Restructuring 
and Reform Act of 1998, the Internal Revenue Service 
shall prohibit any ex parte communications between offi-
cers in the Internal Revenue Service Independent Office 
of Appeals and other Internal Revenue Service employees 
with respect to any matter pending before such officers. 
(b) TERMINATION
OF
EMPLOYMENT
FOR
MIS-
CONDUCT.—Subject to subsection (c), the Commissioner 
of Internal Revenue shall terminate the employment of 
any employee of the Internal Revenue Service if there is 
a final administrative or judicial determination that such 
employee committed any act or omission prohibited under 
subsection (a) in the performance of the employee’s official 
duties. Such termination shall be a removal for cause on 
charges of misconduct. 
(c) DETERMINATION OF COMMISSIONER.— 
(1) IN GENERAL.—The Commissioner of Inter-
nal Revenue may take a personnel action other than 
termination for an act prohibited under subsection 
(a). 
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(2) DISCRETION.—The exercise of authority 
under paragraph (1) shall be at the sole discretion 
of the Commissioner of Internal Revenue and may 
not be delegated to any other officer. At the sole dis-
cretion of the Commissioner of Internal Revenue, 
such Commissioner may establish a procedure which 
will be used to determine whether an individual 
should be referred to the Commissioner of Internal 
Revenue for a determination by the Commissioner 
under paragraph (1). 
(3) NO
APPEAL.—Any determination of the 
Commissioner of Internal Revenue under this sub-
section may not be appealed in any administrative or 
judicial proceeding. 
(d) TIGTA REPORTING OF TERMINATION OR MITI-
GATION.—Section 7803(d)(1)(E) of the Internal Revenue 
Code of 1986 is amended by inserting ‘‘or section 6 of 
the Small Business Taxpayer Bill of Rights Act of 2025’’ 
after ‘‘1998’’. 
SEC. 7. RIGHT TO INDEPENDENT CONFERENCE. 
Section 1001 of the Internal Revenue Service Re-
structuring and Reform Act of 1998 is amended by redes-
ignating subsection (c) as subsection (d) and by inserting 
after subsection (b) the following new subsection: 
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‘‘(c) RIGHT
TO
INDEPENDENT
CONFERENCE.— 
Under the organization plan of the Internal Revenue Serv-
ice, a taxpayer shall have the right to a conference with 
the Internal Revenue Service Independent Office of Ap-
peals which does not include personnel from the Office of 
Chief Counsel for the Internal Revenue Service or the 
compliance functions of the Internal Revenue Service un-
less the taxpayer specifically consents to the participation 
of such personnel.’’. 
SEC. 
8. 
ALTERNATIVE 
DISPUTE 
RESOLUTION 
PROCE-
DURES. 
(a) IN GENERAL.—Section 7123 of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following new subsection: 
‘‘(d) AVAILABILITY OF DISPUTE RESOLUTIONS.— 
‘‘(1) IN GENERAL.—The procedures prescribed 
under subsection (b)(1) and the pilot program estab-
lished under subsection (b)(2) shall provide that a 
taxpayer may request mediation or arbitration in 
any case unless the Secretary has specifically ex-
cluded the type of issue involved in such case or the 
class of cases to which such case belongs as not ap-
propriate for resolution under such subsection. The 
Secretary shall make any determination that ex-
cludes a type of issue or a class of cases public with-
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in 5 working days and provide an explanation for 
each determination. 
‘‘(2) INDEPENDENT MEDIATORS.— 
‘‘(A) IN GENERAL.—The procedures pre-
scribed under subsection (b)(1) shall provide 
the taxpayer an opportunity to elect to have the 
mediation conducted by an independent, neutral 
individual not employed by the Internal Rev-
enue Service Independent Office of Appeals. 
‘‘(B) COST AND SELECTION.— 
‘‘(i) 
IN
GENERAL.—Any 
taxpayer 
making an election under subparagraph 
(A) shall be required— 
‘‘(I) to share the costs of such 
independent mediator equally with the 
Internal Revenue Service Independent 
Office of Appeals, and 
‘‘(II) to limit the selection of the 
mediator to a roster of recognized na-
tional or local neutral mediators. 
‘‘(ii) EXCEPTION.—Clause (i)(I) shall 
not apply to any taxpayer who is an indi-
vidual or who was a small business in the 
preceding calendar year if such taxpayer 
had an adjusted gross income that did not 
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exceed 250 percent of the poverty level, as 
determined in accordance with criteria es-
tablished by the Director of the Office of 
Management and Budget, in the taxable 
year preceding the request. 
‘‘(iii) SMALL
BUSINESS.—For pur-
poses of clause (ii), the term ‘small busi-
ness’ has the meaning given such term 
under section 41(b)(3)(D)(iii). 
‘‘(3) AVAILABILITY OF PROCESS.—The proce-
dures prescribed under subsection (b)(1) and the 
pilot program established under subsection (b)(2) 
shall provide the opportunity to elect mediation or 
arbitration at the time when the case is first filed 
with the Internal Revenue Service Independent Of-
fice of Appeals and at any time before deliberations 
in the appeal commence.’’. 
(b) EFFECTIVE DATE.—The amendment made by 
this section shall take effect on the date of the enactment 
of this Act. 
SEC. 9. INCREASE IN MONETARY PENALTIES FOR CERTAIN 
UNAUTHORIZED DISCLOSURES OF INFORMA-
TION. 
(a) IN GENERAL.—Paragraphs (1), (2), (3), and (4) 
of section 7213(a) of the Internal Revenue Code of 1986 
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are each amended by striking ‘‘$5,000’’ and inserting 
‘‘$10,000’’. 
(b) ADJUSTMENT FOR INFLATION.—Subsection (a) 
of section 7213 of the Internal Revenue Code of 1986 is 
amended by adding at the end the following new para-
graph: 
‘‘(6) ADJUSTMENT
FOR
INFLATION.—In the 
case of any calendar year after 2025, the $10,000 
amounts in paragraphs (1), (2), (3), and (4) shall 
each be increased by an amount equal to— 
‘‘(A) such dollar amount, multiplied by 
‘‘(B) the cost-of-living adjustment deter-
mined under section 1(f)(3) for such calendar 
year, determined by substituting ‘calendar year 
2023’ for ‘calendar year 2016’ in subparagraph 
(A)(ii) thereof. 
If any amount as increased under the preceding sen-
tence is not a multiple of $100, such amount shall 
be rounded to the next lowest multiple of $100.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to disclosures made after the date 
of the enactment of this Act. 
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SEC. 10. BAN ON RAISING NEW ISSUES ON APPEAL. 
(a) IN GENERAL.—Chapter 77 of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following new section: 
‘‘SEC. 7531. PROHIBITION ON INTERNAL REVENUE SERVICE 
RAISING NEW ISSUES IN AN INTERNAL AP-
PEAL. 
‘‘(a) IN GENERAL.—In reviewing an appeal of any 
determination initially made by the Internal Revenue 
Service, the Internal Revenue Service Independent Office 
of Appeals may not consider or decide any issue that is 
not within the scope of the initial determination. 
‘‘(b) CERTAIN ISSUES DEEMED OUTSIDE OF SCOPE 
OF DETERMINATION.—For purposes of subsection (a), the 
following matters shall be considered to be not within the 
scope of a determination: 
‘‘(1) Any issue that was not raised in a notice 
of deficiency or an examiner’s report which is the 
subject of the appeal. 
‘‘(2) Any deficiency in tax which was not in-
cluded in the initial determination. 
‘‘(3) Any theory or justification for a tax defi-
ciency which was not considered in the initial deter-
mination. 
‘‘(c) NO INFERENCE WITH RESPECT
TO ISSUES 
RAISED BY TAXPAYERS.—Nothing in this section shall be 
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construed to provide any limitation in addition to any limi-
tations in effect on the date of the enactment of this sec-
tion on the right of a taxpayer to raise an issue, theory, 
or justification on an appeal from a determination initially 
made by the Internal Revenue Service that was not within 
the scope of the initial determination.’’. 
(b) CLERICAL AMENDMENT.—The table of sections 
for chapter 77 of the Internal Revenue Code of 1986 is 
amended by adding at the end the following new item: 
‘‘Sec. 7531. Prohibition on Internal Revenue Service raising new issues in an 
internal appeal.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to matters filed or pending with 
the Internal Revenue Service Independent Office of Ap-
peals on or after the date of the enactment of this Act. 
SEC. 11. LIMITATION ON ENFORCEMENT OF LIENS AGAINST 
PRINCIPAL RESIDENCES. 
(a) IN GENERAL.—Section 7403(a) of the Internal 
Revenue Code of 1986 is amended— 
(1) by striking ‘‘In any case’’ and inserting the 
following: 
‘‘(1) IN GENERAL.—In any case’’; and 
(2) by adding at the end the following new 
paragraph: 
‘‘(2) LIMITATION WITH RESPECT TO PRINCIPAL 
RESIDENCE.— 
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‘‘(A) IN
GENERAL.—Paragraph (1) shall 
not apply to any property used as the principal 
residence of the taxpayer (within the meaning 
of section 121) unless the Secretary of the 
Treasury makes a written determination that— 
‘‘(i) all other property of the taxpayer, 
if sold, is insufficient to pay the tax or dis-
charge the liability, and 
‘‘(ii) such action will not create an 
economic hardship for the taxpayer. 
‘‘(B) DELEGATION.—For purposes of this 
paragraph, the Secretary of the Treasury may 
not delegate any responsibilities under subpara-
graph (A) to any person other than— 
‘‘(i) the Commissioner of Internal 
Revenue, or 
‘‘(ii) a district director or assistant 
district director of the Internal Revenue 
Service.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to actions filed after the date of 
the enactment of this Act. 
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SEC. 12. ADDITIONAL PROVISIONS RELATING TO MANDA-
TORY TERMINATION FOR MISCONDUCT. 
(a) TERMINATION OF UNEMPLOYMENT FOR INAP-
PROPRIATE REVIEW OF TAX-EXEMPT STATUS.—Section 
1203(b) of the Internal Revenue Service Restructuring 
and Reform Act of 1998 (26 U.S.C. 7804 note) is amend-
ed by striking ‘‘and’’ at the end of paragraph (9), by strik-
ing the period at the end of paragraph (10) and inserting 
‘‘; and’’, and by adding at the end the following new para-
graph: 
‘‘(11) in the case of any review of an applica-
tion for tax-exempt status by an organization de-
scribed in section 501(c) of the Internal Revenue 
Code of 1986, developing or using any methodology 
that applies disproportionate scrutiny to any appli-
cant based on the ideology expressed in the name or 
purpose of the organization.’’. 
(b) MANDATORY UNPAID ADMINISTRATIVE LEAVE 
FOR MISCONDUCT.—Paragraph (1) of section 1203(c) of 
the Internal Revenue Service Restructuring and Reform 
Act of 1998 (26 U.S.C. 7804 note) is amended by adding 
at the end the following new sentence: ‘‘Notwithstanding 
the preceding sentence, if the Commissioner of Internal 
Revenue takes a personnel action other than termination 
for an act or omission described in subsection (b), the 
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Commissioner shall place the employee on unpaid adminis-
trative leave for a period of not less than 90 days.’’. 
(c) LIMITATION ON ALTERNATIVE PUNISHMENT.— 
Paragraph (1) of section 1203(c) of the Internal Revenue 
Service Restructuring and Reform Act of 1998 (26 U.S.C. 
7804 note) is amended by striking ‘‘The Commissioner’’ 
and inserting ‘‘Except in the case of an act or omission 
described in subsection (b)(3)(A), the Commissioner’’. 
SEC. 13. REVIEW BY THE TREASURY INSPECTOR GENERAL 
FOR TAX ADMINISTRATION. 
(a) REVIEW.—Subsection (k)(1) of section 412 of 
title 5, United States Code, is amended— 
(1) in subparagraph (C), by striking ‘‘and’’ at 
the end; 
(2) by redesignating subparagraph (D) as sub-
paragraph (E); 
(3) by inserting after subparagraph (C) the fol-
lowing new subparagraph: 
‘‘(D) shall— 
‘‘(i) review any criteria employed by 
the Internal Revenue Service to select tax 
returns (including applications for recogni-
tion of tax-exempt status) for examination 
or audit, assessment or collection of defi-
ciencies, criminal investigation or referral, 
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refunds for amounts paid, or any height-
ened scrutiny or review in order to deter-
mine whether the criteria discriminates 
against taxpayers on the basis of race, reli-
gion, or political ideology; and 
‘‘(ii) consult with the Internal Rev-
enue Service on recommended amendments 
to such criteria in order to eliminate any 
discrimination identified pursuant to the 
review described in clause (i); and’’; and 
(4) in subparagraph (E), as so redesignated, by 
striking ‘‘and (C)’’ and inserting ‘‘(C), and (D)’’. 
(b) SEMIANNUAL REPORT.—Subsection (g) of section 
412 of title 5, United States Code, is amended by adding 
at the end the following new paragraph: 
‘‘(3) SEMIANNUAL REPORTS.—Any semiannual 
report made by the Treasury Inspector General for 
Tax Administration that is required pursuant to sec-
tion 405(b) shall include— 
‘‘(A) a statement affirming that the Treas-
ury Inspector General for Tax Administration 
has reviewed the criteria described in subsection 
(k)(1)(D) and consulted with the Internal Rev-
enue Service regarding such criteria; and 
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‘‘(B) a description and explanation of any 
such criteria that was identified as discrimina-
tory by the Treasury Inspector General for Tax 
Administration.’’. 
SEC. 14. DEDUCTION FOR EXPENSES RELATING TO CER-
TAIN AUDITS. 
(a) IN GENERAL.—Subsection (a) of section 62 of the 
Internal Revenue Code of 1986 is amended by inserting 
after paragraph (21) the following new paragraph: 
‘‘(22) EXPENSES RELATING TO CERTAIN AU-
DITS.—The deduction allowed by section 224.’’. 
(b) DEDUCTION FOR EXPENSES RELATING TO CER-
TAIN AUDITS.—Part VII of subchapter B of chapter 1 of 
the Internal Revenue Code of 1986 is amended by redesig-
nating section 224 as section 225 and by inserting after 
section 223 the following new section: 
‘‘SEC. 224. EXPENSES RELATING TO CERTAIN AUDITS. 
‘‘(a) ALLOWANCE OF DEDUCTION.—In the case of an 
individual, there shall be allowed as a deduction for the 
taxable year an amount equal to so much of the qualified 
NRP expenses paid or incurred during the taxable year 
as does not exceed $5,000. 
‘‘(b) QUALIFIED NRP EXPENSES.—For purposes of 
this section, the term ‘qualified NRP expenses’ means 
amounts which but for subsection (c) would be allowed as 
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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 2025. 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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