IIB 
115TH CONGRESS 
2D SESSION 
H. R. 5444 
IN THE SENATE OF THE UNITED STATES 
APRIL 19, 2018 
Received; read twice and referred to the Committee on Finance 
AN ACT 
To amend the Internal Revenue Code of 1986 to modernize 
and improve the Internal Revenue Service, to amend 
the Internal Revenue Code of 1986 to make permanent 
the Volunteer Income Tax Assistance matching grant 
program, to require the Secretary of the Treasury to 
establish a program for the issuance of identity protec-
tion personal identification numbers, to amend the Inter-
nal Revenue Code of 1986 to allow officers and employ-
ees of the Department of the Treasury to provide to 
taxpayers information regarding low-income taxpayer 
clinics, to provide for a single point of contact at the 
Internal Revenue Service for the taxpayers who are vic-
tims of tax-related identity theft, to require notice from 
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the Secretary of the Treasury in the case of any closure 
of a Taxpayer Assistance Center, to amend the Internal 
Revenue Code of 1986 to require electronic filing of 
the annual returns of exempt organizations and provide 
for making such returns available for public inspection, 
to amend the Internal Revenue Code of 1986 to improve 
cybersecurity and taxpayer identity protection, and mod-
ernize the information technology of the Internal Rev-
enue Service, to amend the Internal Revenue Code of 
1986 to restrict the immediate sale of seized property 
by the Secretary of the Treasury to perishable goods, 
and for other purposes. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. ORGANIZATION OF ACT INTO DIVISIONS; TABLE 
OF CONTENTS. 
(a) DIVISIONS.—This Act is organized into nine divi-
sions as follows: 
(1) Division A—Taxpayer First Act. 
(2) Division B—Return Preparation programs 
for Low-Income Taxpayers. 
(3) Division C—Identity Protection Personal 
Identification Numbers. 
(4) Division D—Provision of Information Re-
garding Low-Income Taxpayer Clinics. 
(5) Division E—Single Point of Contact for 
Tax-Related Identity Theft Victims. 
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(6) Division F—Notice From IRS Regarding 
Closure of Taxpayer Assistance Center. 
(7) Division G—Mandatory Electronic Filing 
for Annual Returns of Exempt Organizations. 
(8) Division H—21st Century IRS Act. 
(9) Division I—Rules for Seizure and Sale of 
Perishable Goods Restricted to Only Perishable 
Goods. 
(b) TABLE OF CONTENTS.—The table of contents for 
this Act is as follows: 
Sec. 1. Organization of Act into divisions; table of contents. 
DIVISION A—TAXPAYER FIRST ACT 
Sec. 10001. Short title; etc. 
TITLE I—INDEPENDENT APPEALS PROCESS 
Sec. 11101. Establishment of Internal Revenue Service Independent Office of 
Appeals. 
TITLE II—IMPROVED SERVICE 
Sec. 11201. Comprehensive customer service strategy. 
Sec. 11202. IRS Free File Program. 
Sec. 11203. Low-income exception for payments otherwise required in connec-
tion with a submission of an offer-in-compromise. 
TITLE III—SENSIBLE ENFORCEMENT 
Sec. 11301. Internal Revenue Service seizure requirements with respect to 
structuring transactions. 
Sec. 11302. Exclusion of interest received in action to recover property seized 
by the Internal Revenue Service based on structuring trans-
action. 
Sec. 11303. Clarification of equitable relief from joint liability. 
Sec. 11304. Modification of procedures for issuance of third-party summons. 
Sec. 11305. Establishment of income threshold for referral to private debt col-
lection. 
Sec. 11306. Reform of notice of contact of third parties. 
Sec. 11307. Modification of authority to issue designated summons. 
Sec. 11308. Limitation on access of non-Internal Revenue Service employees to 
returns and return information. 
TITLE IV—ORGANIZATIONAL MODERNIZATION 
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Sec. 11401. Modification of title of Commissioner of Internal Revenue and re-
lated officials. 
Sec. 11402. Office of the National Taxpayer Advocate. 
Sec. 11403. Elimination of IRS Oversight Board. 
Sec. 11404. Modernization of Internal Revenue Service organizational struc-
ture. 
TITLE V—TAX COURT 
Sec. 11501. Disqualification of judge or magistrate judge of the Tax Court. 
Sec. 11502. Opinions and judgments. 
Sec. 11503. Title of special trial judge changed to magistrate judge of the Tax 
Court. 
Sec. 11504. Repeal of deadwood related to Board of Tax Appeals. 
DIVISION B—RETURN PREPARATION PROGRAMS FOR LOW- 
INCOME TAXPAYERS 
Sec. 12001. Return preparation programs for low-income taxpayers. 
DIVISION C—IDENTITY PROTECTION PERSONAL IDENTIFICATION 
NUMBERS 
Sec. 13001. Identity protection personal identification numbers. 
DIVISION D—PROVISION OF INFORMATION REGARDING LOW- 
INCOME TAXPAYER CLINICS 
Sec. 14001. Provision of information regarding low-income taxpayer clinics. 
DIVISION E—SINGLE POINT OF CONTACT FOR TAX-RELATED 
IDENTITY THEFT VICTIMS 
Sec. 15001. Single point of contact for tax-related identity theft victims. 
DIVISION F—NOTICE FROM IRS REGARDING CLOSURE OF 
TAXPAYER ASSISTANCE CENTER 
Sec. 16001. Notice from IRS regarding closure of taxpayer assistance centers. 
DIVISION G—MANDATORY ELECTRONIC FILING FOR ANNUAL 
RETURNS OF EXEMPT ORGANIZATIONS 
Sec. 17001. Mandatory electronic filing for annual returns of exempt organiza-
tions. 
DIVISION H—21ST CENTURY IRS ACT 
Sec. 18001. Short title; etc. 
TITLE I—CYBERSECURITY AND IDENTITY PROTECTION 
Sec. 18101. Public-private partnership to address identity theft refund fraud. 
Sec. 18102. Recommendations of Electronic Tax Administration Advisory Com-
mittee regarding identity theft refund fraud. 
Sec. 18103. Information sharing and analysis center. 
Sec. 18104. Compliance by contractors with confidentiality safeguards. 
Sec. 18105. Report on electronic payments. 
TITLE II—DEVELOPMENT OF INFORMATION TECHNOLOGY 
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Sec. 18201. Management of Internal Revenue Service information technology. 
Sec. 18202. Development of online accounts and portals. 
Sec. 18203. Internet platform for Form 1099 filings. 
TITLE III—MODERNIZATION OF CONSENT-BASED INCOME 
VERIFICATION SYSTEM 
Sec. 18301. Disclosure of taxpayer information for third-party income 
verification. 
Sec. 18302. Limit redisclosures and uses of consent-based disclosures of tax re-
turn information. 
TITLE IV—EXPANDED USE OF ELECTRONIC SYSTEMS 
Sec. 18401. Electronic filing of returns. 
Sec. 18402. Uniform standards for the use of electronic signatures for disclo-
sure authorizations to, and other authorizations of, practi-
tioners. 
Sec. 18403. Payment of taxes by debit and credit cards. 
DIVISION I—RULES FOR SEIZURE AND SALE OF PERISHABLE 
GOODS RESTRICTED TO ONLY PERISHABLE GOODS 
Sec. 19001. Rules for seizure and sale of perishable goods restricted to only 
perishable goods. 
DIVISION A—TAXPAYER FIRST 
ACT 
SEC. 10001. SHORT TITLE; ETC. 
(a) SHORT TITLE.—This division may be cited as the 
‘‘Taxpayer First Act’’. 
(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 of 
this division is as follows: 
Sec. 10001. Short title; etc. 
TITLE I—INDEPENDENT APPEALS PROCESS 
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Sec. 11101. Establishment of Internal Revenue Service Independent Office of 
Appeals. 
TITLE II—IMPROVED SERVICE 
Sec. 11201. Comprehensive customer service strategy. 
Sec. 11202. IRS Free File Program. 
Sec. 11203. Low-income exception for payments otherwise required in connec-
tion with a submission of an offer-in-compromise. 
TITLE III—SENSIBLE ENFORCEMENT 
Sec. 11301. Internal Revenue Service seizure requirements with respect to 
structuring transactions. 
Sec. 11302. Exclusion of interest received in action to recover property seized 
by the Internal Revenue Service based on structuring trans-
action. 
Sec. 11303. Clarification of equitable relief from joint liability. 
Sec. 11304. Modification of procedures for issuance of third-party summons. 
Sec. 11305. Establishment of income threshold for referral to private debt col-
lection. 
Sec. 11306. Reform of notice of contact of third parties. 
Sec. 11307. Modification of authority to issue designated summons. 
Sec. 11308. Limitation on access of non-Internal Revenue Service employees to 
returns and return information. 
TITLE IV—ORGANIZATIONAL MODERNIZATION 
Sec. 11401. Modification of title of Commissioner of Internal Revenue and re-
lated officials. 
Sec. 11402. Office of the National Taxpayer Advocate. 
Sec. 11403. Elimination of IRS Oversight Board. 
Sec. 11404. Modernization of Internal Revenue Service organizational struc-
ture. 
TITLE V—TAX COURT 
Sec. 11501. Disqualification of judge or magistrate judge of the Tax Court. 
Sec. 11502. Opinions and judgments. 
Sec. 11503. Title of special trial judge changed to magistrate judge of the Tax 
Court. 
Sec. 11504. Repeal of deadwood related to Board of Tax Appeals. 
TITLE I—INDEPENDENT 
APPEALS PROCESS 
SEC. 11101. 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.— 
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‘‘(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 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 Ad-
ministrator of the Internal Revenue Service 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 Ap-
peals shall be appointed by the Administrator 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— 
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‘‘(i) administration of, and compliance 
with, Federal tax laws, 
‘‘(ii) a broad range of compliance 
cases, and 
‘‘(iii) management of large service or-
ganizations. 
‘‘(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 litigation on a basis which— 
‘‘(A) is fair and impartial to both the Gov-
ernment and the taxpayer, 
‘‘(B) promotes a consistent application and 
interpretation of, and voluntary compliance 
with, the Federal tax laws, and 
‘‘(C) enhances public confidence in the in-
tegrity and efficiency of the Internal Revenue 
Service. 
‘‘(4) RIGHT OF APPEAL.—The resolution proc-
ess 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.— 
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‘‘(A) IN GENERAL.—If any taxpayer which 
is in receipt of notice of deficiency authorized 
under section 6212 requests referral to the In-
ternal Revenue Service Independent Office of 
Appeals and such request is denied, the Admin-
istrator of the Internal Revenue Service shall 
provide such taxpayer a written notice which— 
‘‘(i) provides a detailed description of 
the facts involved, the basis for the deci-
sion to deny the request, and a detailed ex-
planation of how the basis of such decision 
applies to such facts, and 
‘‘(ii) describes the procedures pro-
scribed under subparagraph (C) for pro-
testing the decision to deny the request. 
‘‘(B) REPORT TO CONGRESS.—The Admin-
istrator of the Internal Revenue Service shall 
submit a written report to Congress on an an-
nual basis which includes the number of re-
quests described in subparagraph (A) which 
were denied and the reasons (described by cat-
egory) that such requests were denied. 
‘‘(C) PROCEDURES FOR PROTESTING DE-
NIAL OF REQUEST.—The Administrator of the 
Internal Revenue Service shall prescribe proce-
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dures for protesting to the Administrator of the 
Internal Revenue Service (personally and not 
through any delegate) a denial of a request de-
scribed in subparagraph (A). 
‘‘(D) NOT APPLICABLE TO FRIVOLOUS PO-
SITIONS.—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 Revenue 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 
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 
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who are not involved in preparing such case for 
litigation. 
‘‘(7) ACCESS TO CASE FILES.— 
‘‘(A) IN
GENERAL.—In the case of any 
specified taxpayer with respect to which a con-
ference with the Internal Revenue Service Inde-
pendent Office of Appeals has been scheduled, 
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 Serv-
ice) not later than 10 days before the date of 
such conference. 
‘‘(B) TAXPAYER ELECTION TO EXPEDITE 
CONFERENCE.—If the taxpayer so elects, sub-
paragraph (A) shall be applied by substituting 
‘the date of such conference’ for ‘10 days before 
the date of such conference’. 
‘‘(C) SPECIFIED
TAXPAYER.—For pur-
poses of this paragraph— 
‘‘(i) IN GENERAL.—The term ‘speci-
fied taxpayer’ means— 
‘‘(I) in the case of any taxpayer 
who is a natural person, a taxpayer 
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whose adjusted gross income does not 
exceed $400,000, and 
‘‘(II) in the case of any other 
taxpayer, a taxpayer whose gross re-
ceipts do not exceed $5,000,000. 
‘‘(ii) 
AGGREGATION
RULE.—Rules 
similar to the rules of section 448(c)(2) 
shall apply for purposes of clause (i)(II).’’. 
(b) CONFORMING AMENDMENTS.— 
(1) The following provisions are each amended 
by striking ‘‘Internal Revenue Service Office of Ap-
peals’’ and inserting ‘‘Internal Revenue Service 
Independent Office of Appeals’’: 
(A) Section 6015(c)(4)(B)(ii)(I). 
(B) Section 6320(b)(1). 
(C) Subsections (b)(1) and (d)(3) of sec-
tion 6330. 
(D) Section 6603(d)(3)(B). 
(E) Section 6621(c)(2)(A)(i). 
(F) Section 7122(e)(2). 
(G) Subsections (a), (b)(1), (b)(2), and 
(c)(1) of section 7123. 
(H) Subsections (c)(7)(B)(i, and (g)(2)(A) 
of section 7430. 
(I) Section 7522(b)(3). 
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(J) Section 7612(c)(2)(A). 
(2) Section 7430(c)(2) is amended by striking 
‘‘Internal Revenue Service Office of Appeals’’ each 
place it appears and inserting ‘‘Internal Revenue 
Service Independent Office of Appeals’’. 
(3) The heading of section 6330(d)(3) is 
amended by inserting ‘‘INDEPENDENT’’ after ‘‘IRS’’. 
(c) OTHER REFERENCES.—Any reference in any pro-
vision of law, or regulation or other guidance, to the Inter-
nal Revenue Service Office of Appeals shall be treated as 
a reference to the Internal Revenue Service Independent 
Office of Appeals. 
(d) SAVINGS PROVISIONS.—Rules similar to the rules 
of paragraphs (2) through (6) of section 1001(b) of the 
Internal 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 pro-
vided in this subsection, the amendments made by 
this section shall take effect on the date of the en-
actment 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 
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occurring after the date which is 1 year after the 
date of the enactment of this Act. 
TITLE II—IMPROVED SERVICE 
SEC. 11201. 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 
Secretary of the Treasury, after consultation with the Na-
tional Taxpayer Advocate, shall submit to Congress a writ-
ten comprehensive customer service strategy for the Inter-
nal 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, 
including online services, telephone call back serv-
ices, and training of employees providing customer 
services, 
(2) a thorough assessment of the services that 
the Internal Revenue Service can co-locate with 
other Federal services or offer as self-service op-
tions, 
(3) proposals to improve Internal Revenue Serv-
ice customer service in the short term (the current 
and following fiscal year), medium term (approxi-
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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 
Revenue Service in implementing such strategy. 
(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 shall make 
available the updated guidance and training materials de-
scribed in subsection (a)(4) (including the Internal Rev-
enue Manual). Such updated guidance and training mate-
rials (including the Internal Revenue Manual) shall be 
written in a manner so as to be easily understood by cus-
tomer service employees of the Internal Revenue Service 
and shall provide clear instructions. 
SEC. 11202. 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 
Revenue Service and published in the Federal Reg-
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ister on November 4, 2002 (67 Fed. Reg. 67247), 
including any subsequent agreements and governing 
rules established 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-
ternal Revenue Service annually based on prior year 
aggregate taxpayer adjusted gross income data. 
(3) In addition to the services described in 
paragraph (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 pro-
vide 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 co-
operatively with State government agencies to en-
hance and expand the use of the program to provide 
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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 
implement, consistent with applicable law, innovative new 
program features to improve and simplify the taxpayer’s 
experience with completing and filing individual income 
tax returns through voluntary compliance. 
SEC. 11203. 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 
adding 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 in-
formation is available, which does not exceed 250 
percent of the applicable poverty level (as deter-
mined by the Secretary).’’. 
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(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. 
TITLE III—SENSIBLE 
ENFORCEMENT 
SEC. 11301. 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: 
‘‘(A) IN GENERAL.—Any property’’; and 
(2) by adding at the end the following: 
‘‘(B) INTERNAL
REVENUE
SERVICE
SEI-
ZURE
REQUIREMENTS
WITH
RESPECT
TO 
STRUCTURING TRANSACTIONS.— 
‘‘(i) PROPERTY DERIVED FROM AN IL-
LEGAL
SOURCE.—Property may only be 
seized by the Internal Revenue Service 
pursuant 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 
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of a criminal law or regulation other than 
section 5324. 
‘‘(ii) NOTICE.—Not later than 30 
days after property is seized by the Inter-
nal Revenue Service pursuant to subpara-
graph (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 
with a notice of the seizure and of the 
person’s rights under clause (iv). 
‘‘(iii) EXTENSION OF NOTICE UNDER 
CERTAIN
CIRCUMSTANCES.—The Internal 
Revenue Service may apply to a court of 
competent jurisdiction for one 30-day ex-
tension of the notice requirement under 
clause (ii) if the Internal Revenue Service 
can establish probable cause of an immi-
nent threat to national security or personal 
safety necessitating such extension. 
‘‘(iv) POST-SEIZURE
HEARING.—If a 
person with a property interest in property 
seized pursuant to subparagraph (A) by 
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the Internal Revenue Service requests a 
hearing by a court of competent jurisdic-
tion within 30 days after the date on which 
notice 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 pro-
vide, but only on request of an interested 
party) that there is probable cause to be-
lieve 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 an illegal source or 
the funds were structured for the purpose 
of concealing the violation of a criminal 
law or regulation other than section 
5324.’’. 
SEC. 11302. 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 chap-
ter 1 is amended by inserting before section 140 the fol-
lowing new section: 
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‘‘SEC. 139G. 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 
inserting before the item relating to section 140 the fol-
lowing new item: 
‘‘Sec. 139G. Interest received in action to recover property seized by the Inter-
nal 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. 11303. 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 
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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 fol-
lows: 
‘‘(f) EQUITABLE RELIEF.— 
‘‘(1) IN
GENERAL.—Under procedures pre-
scribed 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 
‘‘(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 re-
lief 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-
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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 
individual could submit a timely claim for re-
fund 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. 
11304. 
MODIFICATION 
OF 
PROCEDURES 
FOR 
ISSUANCE OF THIRD-PARTY SUMMONS. 
(a) IN GENERAL.—Section 7609(f) is amended by 
adding 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 per-
tains 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 
of the enactment of this Act. 
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SEC. 11305. ESTABLISHMENT OF INCOME THRESHOLD FOR 
REFERRAL TO PRIVATE DEBT COLLECTION. 
(a) IN GENERAL.—Section 6306(d)(3) is amended by 
striking ‘‘or’’ at the end of subparagraph (C), by adding 
‘‘or’’ at the end of subparagraph (D), and by inserting 
after subparagraph (D) the following new subparagraph: 
‘‘(E) in the case of a tax receivable which 
is identified by the Secretary (or the Secretary’s 
delegate) during the period beginning on the 
date which is 180 days after the date of the en-
actment of this Act and ending on December 
31, 2019, a taxpayer who is an individual with 
adjusted gross income, as determined for the 
most recent taxable year for which such infor-
mation is available, which does not exceed 250 
percent of the applicable poverty level (as deter-
mined by the Secretary),’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to tax receivables identified by the 
Secretary (or the Secretary’s delegate) after the date 
which is 180 days after the date of the enactment of this 
Act. 
SEC. 11306. REFORM OF NOTICE OF CONTACT OF THIRD 
PARTIES. 
(a) IN GENERAL.—Section 7602(c)(1) is amended to 
read as follows: 
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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 persons made, after the date which is 45 days after 
the date of the enactment of this Act. 
SEC. 11307. MODIFICATION OF AUTHORITY TO ISSUE DES-
IGNATED SUMMONS. 
(a) 
IN
GENERAL.—Clause 
(i) 
of 
section 
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 Administrator of 
the relevant operating division of the Inter-
nal Revenue Service and the Chief Counsel 
which— 
‘‘(I) states facts clearly estab-
lishing that the Secretary has made 
reasonable requests for the informa-
tion that is the subject of the sum-
mons, and 
‘‘(II) is attached to such sum-
mons,’’. 
(b) ESTABLISHMENT THAT REASONABLE REQUESTS 
FOR INFORMATION WERE MADE.—Subsection (j) of sec-
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tion 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 
Secretary shall establish that reasonable requests 
were made for the information that is the subject of 
the summons.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to summonses issued after the date 
of the enactment of this Act. 
SEC. 11308. LIMITATION ON ACCESS OF NON-INTERNAL 
REVENUE SERVICE EMPLOYEES TO RETURNS 
AND RETURN INFORMATION. 
(a) IN GENERAL.—Section 7602 is amended by add-
ing at the end the following new subsection: 
‘‘(f) LIMITATION ON ACCESS OF PERSONS OTHER 
THAN INTERNAL REVENUE SERVICE OFFICERS AND EM-
PLOYEES.—The Secretary shall not, under the authority 
of section 6103(n), provide any books, papers, records, or 
other data obtained pursuant to this section to any person 
authorized under section 6103(n), except when such per-
son requires such information for the sole purpose of pro-
viding expert evaluation and assistance to the Internal 
Revenue Service. No person other than an officer or em-
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ployee of the Internal Revenue Service or the Office of 
Chief Counsel may, on behalf of the Secretary, question 
a witness under oath whose testimony was obtained pursu-
ant to this section.’’. 
(b) EFFECTIVE DATE.— 
(1) IN GENERAL.—Except as provided in para-
graph (2), the amendment made by this section shall 
take effect on the date of the enactment of this Act. 
(2) APPLICATION TO CONTRACTS IN EFFECT.— 
The amendment made by this section shall apply to 
any contract in effect under section 6103(n) of the 
Internal Revenue Code of 1986, pursuant to tem-
porary Treasury Regulation section 301.7602–1T 
proposed in Internal Revenue Bulletin 2014–28, 
Treasury Regulation section 301.7602–1(b)(3), or 
any similar or successor regulation, that is in effect 
on the date of the enactment of this Act. 
TITLE IV—ORGANIZATIONAL 
MODERNIZATION 
SEC. 11401. MODIFICATION OF TITLE OF COMMISSIONER 
OF INTERNAL REVENUE AND RELATED OFFI-
CIALS. 
(a) IN GENERAL.—Section 7803(a)(1)(A) is amended 
by striking ‘‘Commissioner of Internal Revenue’’ and in-
serting ‘‘Administrator of the Internal Revenue Service’’. 
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(b) CONFORMING AMENDMENTS RELATED TO SEC-
TION 7803.— 
(1) Subsections (a)(1)(B), (a)(1)(C), (b)(3), 
(c)(1)(B)(i), and (c)(1)(B)(ii) of section 7803 are 
each amended by striking ‘‘Commissioner of Internal 
Revenue’’ and inserting ‘‘Administrator of the Inter-
nal Revenue Service’’. 
(2) Section 7803(b)(2)(A) is amended by strik-
ing ‘‘Commissioner’s’’ and inserting ‘‘Administra-
tor’s’’. 
(3) Subsections (a)(1)(D), (a)(1)(E), (a)(2), 
(a)(3), 
(a)(4), 
(b)(2)(A), 
(b)(2)(D), 
(b)(3), 
(c)(2)(B)(iii), (c)(2)(C)(iv), and (c)(3) of section 
7803, as amended by the preceding paragraphs of 
this subsection, are amended by striking ‘‘Commis-
sioner’’ each place it appears therein and inserting 
‘‘Administrator’’. 
(4) The heading of section 7803 is amended by 
striking ‘‘COMMISSIONER
OF
INTERNAL
REV-
ENUE’’ and inserting ‘‘ADMINISTRATOR OF THE 
INTERNAL REVENUE SERVICE’’. 
(5) The heading of section 7803(a) is amended 
by striking ‘‘COMMISSIONER
OF INTERNAL REV-
ENUE’’ and inserting ‘‘ADMINISTRATOR OF THE IN-
TERNAL REVENUE SERVICE’’. 
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(6) The heading of section 7803(c)(3) is 
amended by striking ‘‘COMMISSIONER’’ and inserting 
‘‘ADMINISTRATOR’’. 
(7) The table of sections for subchapter A of 
chapter 80 is amended by striking the item relating 
to section 7803 and inserting the following new 
item: 
‘‘Sec. 7803. Administrator of the Internal Revenue Service; other officials.’’. 
(c) OTHER CONFORMING AMENDMENTS TO THE IN-
TERNAL REVENUE CODE OF 1986.— 
(1) Section 6307(c) is amended by striking 
‘‘Commissioner of Internal Revenue’’ and inserting 
‘‘Administrator of the Internal Revenue Service’’. 
(2) Section 6673(a)(2)(B) is amended by strik-
ing ‘‘Commissioner of Internal Revenue’’ and insert-
ing ‘‘Administrator of the Internal Revenue Serv-
ice’’. 
(3) Section 6707(c) is amended by striking 
‘‘Commissioner’’ and inserting ‘‘Administrator’’. 
(4) Section 6707A(d) is amended— 
(A) in paragraph (1), by striking ‘‘Com-
missioner of Internal Revenue’’ and inserting 
‘‘Administrator of the Internal Revenue Serv-
ice’’, and 
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(B) in paragraph (3), by striking ‘‘Com-
missioner’’ each place it appears and inserting 
‘‘Administrator’’. 
(5)(A) Subsections (a) and (g) of section 7345 
are each amended by striking ‘‘Commissioner of In-
ternal Revenue’’ and inserting ‘‘Administrator of the 
Internal Revenue Service’’. 
(B) Section 7345(g) is amended— 
(i) by striking ‘‘Deputy Commissioner for 
Services and Enforcement’’ and inserting ‘‘Dep-
uty Administrator for Services and Enforce-
ment’’, and 
(ii) by striking ‘‘Commissioner of an oper-
ating division’’ and inserting ‘‘Administrator of 
an operating division’’. 
(C) Subsections (c)(1), (d) and (e)(1) of section 
7345 are each amended by striking ‘‘Commissioner’’ 
each place it appears therein and inserting ‘‘Admin-
istrator’’. 
(6) Section 7435(e) is amended by striking 
‘‘Commissioner’’ each place it appears therein and 
inserting ‘‘Administrator’’. 
(7) Section 7409(a)(2)(B) is amended by strik-
ing ‘‘Commissioner of Internal Revenue’’ and insert-
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ing ‘‘Administrator of the Internal Revenue Serv-
ice’’. 
(8) Section 7608(c) is amended— 
(A) in paragraph (1), by striking ‘‘the 
Commissioner of Internal Revenue (or, if des-
ignated by the Commissioner, the Deputy Com-
missioner or an Assistant Commissioner of In-
ternal Revenue)’’ and inserting ‘‘the Adminis-
trator of the Internal Revenue Service (or, if 
designated by the Administrator, the Deputy 
Administrator or an Assistant Administrator of 
the Internal Revenue Service)’’, and 
(B) in paragraph (2) by striking ‘‘Commis-
sioner’’ and inserting ‘‘Administrator’’. 
(9) Section 7611(b)(3)(C) is amended by strik-
ing ‘‘regional commissioner’’ and inserting ‘‘regional 
administrator’’. 
(10) Section 7701(a)(13) is amended to read as 
follows: 
‘‘(13) ADMINISTRATOR.—The term ‘Adminis-
trator’, except where the context clearly indicates 
otherwise, means the Administrator of the Internal 
Revenue Service.’’. 
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(1) IN GENERAL.—Section 7803(c) is amended 
by adding at the end the following new paragraph: 
‘‘(5) TAXPAYER
ADVOCATE
DIRECTIVES.—In 
the case of any Taxpayer Advocate Directive issued 
by the National Taxpayer Advocate pursuant to a 
delegation of authority from the Administrator of 
the Internal Revenue Service— 
‘‘(A) the Administrator or a Deputy Ad-
ministrator shall modify, rescind, or ensure 
compliance with such directive not later than 90 
days after the issuance of such directive, and 
‘‘(B) in the case of any directive which is 
modified or rescinded by a Deputy Adminis-
trator, the National Taxpayer Advocate may 
(not later than 90 days after such modification 
or rescission) appeal to the Administrator and 
the Administrator shall (not later than 90 days 
after such appeal is made) ensure compliance 
with such directive as issued by the National 
Taxpayer Advocate or provide the National 
Taxpayer Advocate with a detailed description 
of the reasons for any modification or rescission 
made or upheld by the Administrator pursuant 
to such appeal.’’. 
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(2) REPORT TO CERTAIN COMMITTEES OF CON-
GRESS
REGARDING
DIRECTIVES.—Section 
7803(c)(2)(B)(ii) is amended by redesignating sub-
clauses (VIII) through (XI) as subclauses (IX) 
through (XII), respectively, and by inserting after 
subclause (VII) the following new subclause: 
‘‘(VIII) identify any Taxpayer 
Advocate Directive which was not 
honored by the Internal Revenue 
Service in a timely manner, as speci-
fied under paragraph (5);’’. 
(b) NATIONAL TAXPAYER ADVOCATE ANNUAL RE-
PORTS TO CONGRESS.— 
(1) INCLUSION
OF
MOST
SERIOUS
TAXPAYER 
PROBLEMS.—Section 
7803(c)(2)(B)(ii)(III) 
is 
amended by striking ‘‘at least 20’’ and inserting 
‘‘the 10’’. 
(2) COORDINATION WITH TREASURY INSPECTOR 
GENERAL
FOR
TAX
ADMINISTRATION.—Section 
7803(c)(2) is amended by adding at the end the fol-
lowing new subparagraph: 
‘‘(E) COORDINATION WITH TREASURY IN-
SPECTOR
GENERAL
FOR
TAX
ADMINISTRA-
TION.—Before beginning any research or study, 
the National Taxpayer Advocate shall coordi-
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nate with the Treasury Inspector General for 
Tax Administration to ensure that the National 
Taxpayer Advocate does not duplicate any ac-
tion that the Treasury Inspector General for 
Tax Administration has already undertaken or 
has a plan to undertake.’’. 
(3) STATISTICAL SUPPORT.— 
(A) IN GENERAL.—Section 6108 is amend-
ed by adding at the end the following new sub-
section: 
‘‘(d) STATISTICAL SUPPORT FOR NATIONAL TAX-
PAYER ADVOCATE.—The Secretary shall, upon request of 
the National Taxpayer Advocate, provide the National 
Taxpayer Advocate with statistical support in connection 
with the preparation by the National Taxpayer Advocate 
of 
the 
annual 
report 
described 
in 
section 
7803(c)(2)(B)(ii). Such statistical support shall include 
statistical studies, compilations, and the review of infor-
mation provided by the National Taxpayer Advocate for 
statistical validity and sound statistical methodology.’’. 
(B) DISCLOSURE
OF
REVIEW.—Section 
7803(c)(2)(B)(ii), as amended by subsection 
(a), is amended by redesignating subclause 
(XII) as subclause (XIII) and by inserting after 
subclause (XI) the following new subclause: 
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‘‘(XII) with respect to any statis-
tical information included in such re-
port, include a statement of whether 
such statistical information was re-
viewed or provided by the Secretary 
under section 6108(d) and, if so, 
whether the Secretary determined 
such information to be statistically 
valid and based on sound statistical 
methodology.’’. 
(C) CONFORMING
AMENDMENT.—Section 
7803(c)(2)(B)(iii) is amended by adding at the 
end the following: ‘‘The preceding sentence 
shall not apply with respect to statistical infor-
mation provided to the Secretary for review, or 
received from the Secretary, under section 
6108(d).’’. 
(c) SALARY OF NATIONAL TAXPAYER ADVOCATE.— 
Section 7803(c)(1)(B)(i) is amended by striking ‘‘, or, if 
the Secretary of the Treasury so determines, at a rate 
fixed under section 9503 of such title’’. 
(d) EFFECTIVE DATE.— 
(1) IN
GENERAL.—Except as otherwise pro-
vided in this subsection, the amendments made by 
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this section shall take effect on the date of the en-
actment of this Act. 
(2) SALARY
OF
NATIONAL
TAXPAYER
ADVO-
CATE.—The amendment made by subsection (c) 
shall apply to compensation paid to individuals ap-
pointed as the National Taxpayer Advocate after the 
date of the enactment of this Act. 
SEC. 11403. ELIMINATION OF IRS OVERSIGHT BOARD. 
(a) IN GENERAL.—Subchapter A of chapter 80 is 
amended by striking section 7802 (and by striking the 
item relating to such section in the table of sections of 
such subchapter). 
(b) CONFORMING AMENDMENTS.— 
(1) Section 4946(c) is amended by adding ‘‘or’’ 
at the end of paragraph (5), by striking ‘‘, or’’ at 
the end of paragraph (6) and inserting a period, and 
by striking paragraph (7). 
(2) Section 6103(h) is amended by striking 
paragraph (6). 
(3) Section 7803(a) is amended by striking 
paragraph (4). 
(4) Section 7803(c)(1)(B)(ii) is amended by 
striking ‘‘and the Oversight Board’’. 
(5) Section 7803(c)(2)(B)(iii) is amended by 
striking ‘‘the Oversight Board,’’. 
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(6) Section 8D of the Inspector General Act of 
1978 is amended— 
(A) in subsections (g)(2) and (h), by strik-
ing ‘‘the Internal Revenue Service Oversight 
Board and’’, 
(B) in subsection (l)(1), by striking ‘‘or the 
Internal Revenue Service Oversight Board’’, 
and 
(C) in subsection (l)(2), by striking ‘‘and 
the Internal Revenue Service Oversight Board’’. 
SEC. 11404. MODERNIZATION OF INTERNAL REVENUE 
SERVICE ORGANIZATIONAL STRUCTURE. 
(a) IN GENERAL.—Not later than September 30, 
2020, the Administrator of the Internal Revenue Service 
shall submit to Congress a comprehensive written plan to 
redesign the organization of the Internal Revenue Service. 
Such plan shall— 
(1) ensure the successful implementation of the 
priorities specified by Congress in this Act, 
(2) prioritize taxpayer services to ensure that 
all taxpayers easily and readily receive the assistance 
that they need, 
(3) streamline the structure of the agency in-
cluding minimizing the duplication of services and 
responsibilities within the agency, 
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