H. R. 3151 
One Hundred Sixteenth Congress 
of the 
United States of America 
AT THE FIRST SESSION 
Begun and held at the City of Washington on Thursday, 
the third day of January, two thousand and nineteen 
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 Representatives 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 considered to be made to a section 
or other provision 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 Ap-
peals. 
Subtitle B—Improved Service 
Sec. 1101. Comprehensive customer service strategy. 
Sec. 1102. 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 re-
turns and return information. 
Subtitle D—Organizational Modernization 
Sec. 1301. Office of the National Taxpayer Advocate. 
Sec. 1302. Modernization of Internal Revenue Service organizational structure. 
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.
H. R. 3151—2 
Sec. 1404. Rules for seizure and sale of perishable goods restricted to only perish-
able 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 Committee 
regarding identity theft refund fraud. 
Sec. 2003. Information sharing and analysis center. 
Sec. 2004. Compliance by contractors with confidentiality safeguards. 
Sec. 2005. Identity protection personal identification numbers. 
Sec. 2006. Single point of contact for tax-related identity theft victims. 
Sec. 2007. Notification of suspected identity theft. 
Sec. 2008. Guidelines for stolen identity refund fraud cases. 
Sec. 2009. Increased penalty for improper disclosure or use of information by pre-
parers 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 positions. 
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 return 
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 au-
thorizations to, and other authorizations of, practitioners. 
Sec. 2303. Payment of taxes by debit and credit cards. 
Sec. 2304. Authentication of users of electronic services accounts. 
Subtitle E—Other Provisions 
Sec. 2401. Repeal of provision regarding certain tax compliance procedures and re-
ports. 
Sec. 2402. Comprehensive training strategy. 
TITLE III—MISCELLANEOUS PROVISIONS 
Subtitle A—Reform of Laws Governing Internal Revenue Service Employees 
Sec. 3001. Prohibition on rehiring any employee of the Internal Revenue Service 
who was involuntarily separated from service for misconduct. 
Sec. 3002. Notification of unauthorized inspection or disclosure of returns and re-
turn 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—Revenue Provision 
Sec. 3201. Increase in penalty for failure to file. 
TITLE IV—BUDGETARY EFFECTS 
Sec. 4001. Determination of budgetary effects.
H. R. 3151—3 
TITLE I—PUTTING TAXPAYERS FIRST 
Subtitle A—Independent Appeals Process 
SEC. 1001. ESTABLISHMENT OF INTERNAL REVENUE SERVICE INDE-
PENDENT 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 Inde-
pendent 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 
Commissioner of Internal Revenue and shall be entitled 
to compensation at the same rate as 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 Commissioner of Internal Revenue with-
out 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 appointed under 
subparagraph (B) shall have experience and expertise in— 
‘‘(i) administration of, and compliance with, Fed-
eral tax laws, 
‘‘(ii) a broad range of compliance cases, and 
‘‘(iii) management of large service organizations. 
‘‘(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 litiga-
tion on a basis which— 
‘‘(A) is fair and impartial to both the Government and 
the taxpayer, 
‘‘(B) promotes a consistent application and interpreta-
tion of, and voluntary compliance with, the Federal tax 
laws, and 
‘‘(C) enhances public confidence in the integrity and 
efficiency of the Internal Revenue Service. 
‘‘(4) RIGHT OF APPEAL.—The resolution process described 
in paragraph (3) shall be generally available to all taxpayers. 
‘‘(5) LIMITATION ON DESIGNATION OF CASES AS NOT ELIGIBLE 
FOR REFERRAL TO INDEPENDENT OFFICE OF APPEALS.— 
‘‘(A) IN GENERAL.—If any taxpayer which is in receipt 
of a notice of deficiency authorized under section 6212 
requests referral to the Internal Revenue Service Inde-
pendent Office of Appeals and such request is denied, the 
Commissioner of Internal Revenue shall provide such tax-
payer a written notice which— 
‘‘(i) provides a detailed description of the facts 
involved, the basis for the decision to deny the request,
H. R. 3151—4 
and a detailed explanation of how the basis of such 
decision applies to such facts, and 
‘‘(ii) describes the procedures prescribed under 
subparagraph (C) for protesting the decision to deny 
the request. 
‘‘(B) REPORT
TO
CONGRESS.—The Commissioner of 
Internal Revenue shall submit a written report to Congress 
on an annual basis which includes the number of requests 
described in subparagraph (A) which were denied and the 
reasons (described by category) that such requests were 
denied. 
‘‘(C) 
PROCEDURES
FOR
PROTESTING
DENIAL
OF 
REQUEST.—The Commissioner of Internal Revenue shall 
prescribe procedures for protesting to the Commissioner 
of Internal Revenue a denial of a request described in 
subparagraph (A). 
‘‘(D) NOT APPLICABLE TO FRIVOLOUS POSITIONS.—This 
paragraph shall not apply to a request for referral to the 
Internal Revenue Service Independent Office of Appeals 
which is denied on the basis that the issue involved is 
a frivolous position (within the meaning of section 6702(c)). 
‘‘(6) STAFF.— 
‘‘(A) IN GENERAL.—All personnel in the Internal Rev-
enue Service Independent Office of Appeals 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 advice from the staff of the 
Office of the Chief Counsel. The Chief Counsel shall ensure, 
to the extent practicable, that such assistance and advice 
is provided by staff of the Office of the Chief Counsel 
who were not involved in the case with respect to which 
such assistance and advice is sought and who are not 
involved in preparing such case for litigation. 
‘‘(7) ACCESS TO CASE FILES.— 
‘‘(A) IN GENERAL.—In any case in which a conference 
with the Internal Revenue Service Independent Office of 
Appeals has been scheduled upon request of a specified 
taxpayer, the Chief of Appeals shall ensure that such tax-
payer is provided 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. 
‘‘(B) TAXPAYER ELECTION TO EXPEDITE CONFERENCE.— 
If the taxpayer so elects, subparagraph (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 para-
graph— 
‘‘(i) IN
GENERAL.—The term ‘specified taxpayer’ 
means— 
‘‘(I) in the case of any taxpayer who is a nat-
ural person, a taxpayer whose adjusted gross 
income does not exceed $400,000 for the taxable 
year to which the dispute relates, and