II 
115TH CONGRESS 
2D SESSION 
H. R. 7227 
IN THE SENATE OF THE UNITED STATES 
DECEMBER 20, 2018 
Received 
AN ACT 
To amend the Internal Revenue Code of 1986 to modernize 
and improve the Internal Revenue Service, and for other 
purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
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SECTION 1. SHORT TITLE; ETC. 
(a) SHORT TITLE.—This Act may be cited as the 
‘‘Taxpayer First Act of 2018’’. 
(b) AMENDMENT OF 1986 CODE.—Except as other-
wise expressly provided, whenever in this Act an amend-
ment or repeal is expressed in terms of an amendment 
to, or repeal of, a section or other provision, the reference 
shall be considered to be made to a section or other provi-
sion of the Internal Revenue Code of 1986. 
(c) TABLE OF CONTENTS.—The table of contents for 
this Act is as follows: 
Sec. 1. Short title; etc. 
TITLE I—PUTTING TAXPAYERS FIRST 
Subtitle A—Independent Appeals Process 
Sec. 1001. Establishment of Internal Revenue Service Independent Office of 
Appeals. 
Subtitle B—Improved Service 
Sec. 1101. Comprehensive customer service strategy. 
Sec. 1102. IRS Free File Program. 
Sec. 1103. Low-income exception for payments otherwise required in connection 
with a submission of an offer-in-compromise. 
Subtitle C—Sensible Enforcement 
Sec. 1201. Internal Revenue Service seizure requirements with respect to struc-
turing transactions. 
Sec. 1202. Exclusion of interest received in action to recover property seized by 
the Internal Revenue Service based on structuring transaction. 
Sec. 1203. Clarification of equitable relief from joint liability. 
Sec. 1204. Modification of procedures for issuance of third-party summons. 
Sec. 1205. Private debt collection and special compliance personnel program. 
Sec. 1206. Reform of notice of contact of third parties. 
Sec. 1207. Modification of authority to issue designated summons. 
Sec. 1208. Limitation on access of non-Internal Revenue Service employees to 
returns and return information. 
Subtitle D—Organizational Modernization 
Sec. 1301. Office of the National Taxpayer Advocate. 
Sec. 1302. Modernization of Internal Revenue Service organizational structure. 
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Subtitle E—Other Provisions 
Sec. 1401. Return preparation programs for applicable taxpayers. 
Sec. 1402. Provision of information regarding low-income taxpayer clinics. 
Sec. 1403. Notice from IRS regarding closure of taxpayer assistance centers. 
Sec. 1404. Rules for seizure and sale of perishable goods restricted to only per-
ishable goods. 
Sec. 1405. Whistleblower reforms. 
Sec. 1406. Customer service information. 
Sec. 1407. Misdirected tax refund deposits. 
TITLE II—21ST CENTURY IRS 
Subtitle A—Cybersecurity and Identity Protection 
Sec. 2001. Public-private partnership to address identity theft refund fraud. 
Sec. 2002. Recommendations of Electronic Tax Administration Advisory Com-
mittee regarding identity theft refund fraud. 
Sec. 2003. Information sharing and analysis center. 
Sec. 2004. Compliance by contractors with confidentiality safeguards. 
Sec. 2005. Report on electronic payments. 
Sec. 2006. Identity protection personal identification numbers. 
Sec. 2007. Single point of contact for tax-related identity theft victims. 
Sec. 2008. Notification of suspected identity theft. 
Sec. 2009. Guidelines for stolen identity refund fraud cases. 
Sec. 2010. Increased penalty for improper disclosure or use of information by 
preparers of returns. 
Subtitle B—Development of Information Technology 
Sec. 2101. Management of Internal Revenue Service information technology. 
Sec. 2102. Internet platform for Form 1099 filings. 
Sec. 2103. Streamlined critical pay authority for information technology posi-
tions. 
Subtitle C—Modernization of Consent-Based Income Verification System 
Sec. 2201. Disclosure 
of 
taxpayer 
information 
for 
third-party 
income 
verification. 
Sec. 2202. Limit redisclosures and uses of consent-based disclosures of tax re-
turn information. 
Subtitle D—Expanded Use of Electronic Systems 
Sec. 2301. Electronic filing of returns. 
Sec. 2302. Uniform standards for the use of electronic signatures for disclosure 
authorizations to, and other authorizations of, practitioners. 
Sec. 2303. Payment of taxes by debit and credit cards. 
Sec. 2304. Requirement that electronically prepared paper returns include scan-
nable code. 
Sec. 2305. Authentication of users of electronic services accounts. 
Subtitle E—Other Provisions 
Sec. 2401. Repeal of provision regarding certain tax compliance procedures and 
reports. 
Sec. 2402. Comprehensive training strategy. 
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TITLE III—MISCELLANEOUS PROVISIONS 
Subtitle A—Reform of Laws Governing Internal Revenue Service Employees 
Sec. 3001. Electronic record retention. 
Sec. 3002. Prohibition on rehiring any employee of the Internal Revenue Serv-
ice who was involuntarily separated from service for mis-
conduct. 
Sec. 3003. Notification of unauthorized inspection or disclosure of returns and 
return information. 
Subtitle B—Provisions Relating to Exempt Organizations 
Sec. 3101. Mandatory e-filing by exempt organizations. 
Sec. 3102. Notice required before revocation of tax exempt status for failure to 
file return. 
Subtitle C—Tax Court 
Sec. 3301. Disqualification of judge or magistrate judge of the Tax Court. 
Sec. 3302. Opinions and judgments. 
Sec. 3303. Title of special trial judge changed to magistrate judge of the Tax 
Court. 
Sec. 3304. Repeal of deadwood related to Board of Tax Appeals. 
TITLE I—PUTTING TAXPAYERS 
FIRST 
Subtitle A—Independent Appeals 
Process 
SEC. 1001. ESTABLISHMENT OF INTERNAL REVENUE SERV-
ICE INDEPENDENT OFFICE OF APPEALS. 
(a) IN GENERAL.—Section 7803 is amended by add-
ing 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.— 
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‘‘(A) IN GENERAL.—The Internal Revenue 
Service Independent Office of Appeals shall be 
under the supervision and direction of an offi-
cial to be known as the ‘Chief of Appeals’. The 
Chief of Appeals shall report directly to the 
Commissioner of the Internal Revenue Service 
and shall be entitled to compensation at the 
same rate as the highest rate of basic pay es-
tablished for the Senior Executive Service under 
section 5382 of title 5, United States Code. 
‘‘(B) APPOINTMENT.—The Chief of Ap-
peals shall be appointed by the Commissioner of 
the Internal Revenue Service without regard to 
the provisions of title 5, United States Code, re-
lating to appointments in the competitive serv-
ice or the Senior Executive Service. 
‘‘(C) QUALIFICATIONS.—An individual ap-
pointed under subparagraph (B) shall have ex-
perience 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. 
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