‘‘(i) IN GENERAL.—After notice and 
opportunity to respond, the Secretary may 
suspend the preparer tax identification 
number of a tax return preparer for a pe-
riod of not greater than 180 days if the 
Secretary determines that— 
‘‘(I) such tax return preparer has 
engaged in any conduct described in 
clauses (i) through (vi) of subpara-
graph (A), and 
‘‘(II) such suspension is nec-
essary to prevent serious economic 
harm to taxpayers or serious impair-
ment of effective tax administration, 
such as to prevent the filing of fraud-
ulent returns or claims for refund. 
‘‘(ii) LIMITATION.—For purposes of 
clause (i), if the preparer tax identification 
number of a tax return preparer has been 
suspended pursuant to such clause 2 times 
during any 5-year period, the Secretary 
may not issue an additional suspension 
pursuant to such clause with respect to 
such preparer during such period unless 
such suspension is subsequent to a deter-
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mination by the Secretary to suspend or 
revoke the preparer tax identification num-
ber of such preparer pursuant to subpara-
graph (A). 
‘‘(E) REGULATIONS.—Not later than 24 
months after the date of enactment of this sub-
section, the Secretary shall issue such regula-
tions or other guidance as the Secretary deter-
mines necessary to carry out the purposes of 
this paragraph, including— 
‘‘(i) guidelines that identify the par-
ticular penalty applicable to any conduct 
described in subparagraph (A), and 
‘‘(ii) the manner of notice and oppor-
tunity to respond for purposes of subpara-
graph (D). 
‘‘(6) APPEAL.—In the case of any tax return 
preparer for whom the Secretary has made a deter-
mination— 
‘‘(A) that such preparer has not met the 
requirements of paragraphs (2) and (3) or of 
paragraph (4) and that issuance of a preparer 
tax identification number should be denied, 
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‘‘(B) under paragraph (5)(A) that the pre-
parer tax identification number for such pre-
parer should be suspended or revoked, or 
‘‘(C) that a penalty should be imposed pur-
suant to paragraph (5)(B), 
such preparer shall be provided with an opportunity 
to appeal such determination to the Internal Rev-
enue Service Independent Office of Appeals pursuant 
to procedures (as established by the Secretary 
through regulations or other guidance) which are 
similar to the procedures provided under section 330 
of title 31, United States Code, or regulations pre-
scribed thereunder. 
‘‘(7) DISCLOSURE
OF
FINAL
DETERMINA-
TIONS.— 
‘‘(A) IN
GENERAL.—In the case of any 
final determination with respect to the extended 
suspension, revocation, reissuance, or termi-
nation of an extended suspension of a preparer 
tax identification number under this subsection, 
not later than 30 days following such deter-
mination, the Secretary shall publish such de-
termination on the public website of the Inter-
nal Revenue Service, which shall include— 
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‘‘(i) a statement of the facts and cir-
cumstances relating to such determination, 
and 
‘‘(ii) the reasons for the determina-
tion. 
‘‘(B) EXTENDED SUSPENSION.—For pur-
poses of subparagraph (A), the term ‘extended 
suspension’ means a suspension issued by the 
Secretary pursuant to paragraph (5)(A) for a 
period of greater than 180 days. 
‘‘(8) PREPARER
TAX
IDENTIFICATION
NUM-
BER.—For purposes of this subsection, the term 
‘preparer tax identification number’ means an iden-
tifying number described in subsection (a)(4)(A).’’. 
(b) INFORMATION RETURNS OF TAX RETURN PRE-
PARERS.—Section 6060 is amended— 
(1) by redesignating subsection (c) as sub-
section (d), and 
(2) by inserting after subsection (b) the fol-
lowing: 
‘‘(c) ADDITIONAL
INFORMATION
FROM
SUPER-
VISORS.—In the case of a person required to make a re-
turn under subsection (a) who is described in section 
6109(a)(4)(B)(ii)(III), such person shall include in such 
return— 
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‘‘(1) the name and taxpayer identification num-
ber of any tax return preparer under their super-
vision and direction who, pursuant to subparagraph 
(B) of section 6109(a)(4), is exempted from the re-
quirement under subparagraph (A) of such section, 
‘‘(2) with respect to each tax return preparer 
described in paragraph (1), whether such preparer is 
employed by such person as of the date on which 
such return is made, and 
‘‘(3) such other information as the Secretary 
determines appropriate.’’. 
(c) DETERMINATIONS REGARDING PRACTICE BE-
FORE THE DEPARTMENT.—Section 330 of title 31, United 
States Code, is amended— 
(1) by redesignating subsection (e) as sub-
section (f); and 
(2) by inserting after subsection (d) the fol-
lowing: 
‘‘(e) DISCLOSURE OF FINAL DETERMINATIONS.—In 
the case of any final determination under subsection (c) 
or (d), not later than 30 days following such determina-
tion, the Secretary shall publish such determination on a 
public website, which shall include— 
‘‘(1) a statement of the facts and circumstances 
relating to such determination, and 
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‘‘(2) the reasons for the determination.’’. 
(d) DISCLOSURE RELATING
TO MISCONDUCT
BY 
PRACTITIONERS AND TAX RETURN PREPARERS.— 
(1) IN GENERAL.—Section 6103(k) is amended 
by adding at the end the following new paragraph: 
‘‘(16) DISCLOSURE RELATING TO MISCONDUCT 
BY PRACTITIONERS AND TAX RETURN PREPARERS.— 
Under such procedures as the Secretary may pre-
scribe, the Secretary may disclose returns and re-
turn information to the extent the Secretary deter-
mines it is necessary to publish determinations pur-
suant to section 6109(e)(7) and section 330(e) of 
title 31, United States Code, provided that such dis-
closure is redacted to remove— 
‘‘(A) any name, address, or other identi-
fying information with respect to any persons 
other than the representative or tax return pre-
parer who is the subject of such determination, 
and 
‘‘(B) such other information as the Sec-
retary determines appropriate to protect the 
privacy of such persons.’’. 
(2) 
CONFORMING
AMENDMENT.—Section 
6103(p)(3)(A) is amended by striking ‘‘or (9)’’ and 
inserting ‘‘(9), or (16)’’. 
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(e) REQUIREMENT TO INCLUDE IDENTIFYING NUM-
BER FOR PAID PREPARER OF OFFER-IN-COMPROMISE.— 
(1) IN GENERAL.—Section 6109(a) is amended 
by inserting after paragraph (4) the following new 
paragraph: 
‘‘(5) FURNISHING IDENTIFYING NUMBER FOR 
OFFER-IN-COMPROMISE.—Any 
offer-in-compromise 
(as described in section 7122) which has been pre-
pared by any person for compensation shall include 
such identifying number as may be prescribed for se-
curing proper identification of such person.’’. 
(2) PENALTY.—Section 7122 is amended by 
adding at the end the following new subsection: 
‘‘(h) FAILURE TO FURNISH IDENTIFYING NUM-
BER.— 
‘‘(1) IN GENERAL.— 
‘‘(A) PENALTY.—Any person who prepares 
an offer-in-compromise for compensation and 
who fails to include an identifying number 
which complies with section 6109(a)(5) with re-
spect to such offer-in-compromise shall pay a 
penalty of $250 for such failure. 
‘‘(B) NON-COMPLIANCE.—For purposes of 
this paragraph, an identifying number shall be 
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deemed to not comply with section 6109(a)(5) 
if such identifying number— 
‘‘(i) is assigned to another person, 
‘‘(ii) does not exist, 
‘‘(iii) is inactive or expired, 
‘‘(iv) has been withdrawn, 
‘‘(v) is suspended or has been revoked, 
or 
‘‘(vi) is otherwise invalid for use by 
the preparer. 
‘‘(C) ADJUSTMENT FOR INFLATION.— 
‘‘(i) IN GENERAL.—In the case of any 
documents filed during any calendar year 
beginning after 2025, the $250 amount in 
subparagraph (A) shall be increased by an 
amount equal to— 
‘‘(I) such dollar amount, multi-
plied by 
‘‘(II) the cost-of-living adjust-
ment determined under section 1(f)(3) 
for the calendar year, determined by 
substituting ‘calendar year 2024’ for 
‘calendar year 2016’ in subparagraph 
(A)(ii) thereof. 
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‘‘(ii) ROUNDING.—If any amount de-
termined under clause (i) is not a multiple 
of $10, such amount shall be rounded to 
the nearest multiple of $10. 
‘‘(2) EXCEPTION.—The penalty imposed under 
paragraph (1) shall not apply if it is shown that 
such failure is due to reasonable cause and not due 
to willful neglect. 
‘‘(3) LIMITATION.— 
‘‘(A) IN GENERAL.—The maximum penalty 
imposed under this subsection on any person 
with respect to documents filed during any cal-
endar year shall not exceed $75,000. 
‘‘(B) ADJUSTMENT FOR INFLATION.— 
‘‘(i) IN GENERAL.—In the case of any 
penalty imposed during any calendar year 
beginning after 2025, the $75,000 amount 
in subparagraph (A) shall be increased by 
an amount equal to— 
‘‘(I) such dollar amount, multi-
plied by 
‘‘(II) the cost-of-living adjust-
ment determined under section 1(f)(3) 
for the calendar year, determined by 
substituting ‘calendar year 2024’ for 
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‘calendar year 2016’ in subparagraph 
(A)(ii) thereof. 
‘‘(ii) ROUNDING.—If any amount de-
termined under clause (i) is not a multiple 
of $1,000, such amount shall be rounded 
to the nearest multiple of $1,000. 
‘‘(4) OTHER APPLICABLE RULES.—Rules simi-
lar to the rules of section 6696 shall apply for pur-
poses of this subsection.’’. 
(f) GAO STUDY AND REPORT ON THE EXCHANGE 
OF INFORMATION BETWEEN THE IRS AND STATE TAX-
ATION AUTHORITIES.— 
(1) IN GENERAL.—Not later than 18 months 
after the date of the enactment of this Act, the 
Comptroller General of the United States shall con-
duct a study and submit to Congress a report on the 
sharing of information between the Secretary and 
State authorities, as authorized under subsections 
(d) and (k)(5) of section 6103 of the Internal Rev-
enue Code of 1986, regarding identification numbers 
issued to paid tax return preparers and return pre-
parer minimum standards. 
(2) INCREASED INFORMATION SHARING.—The 
study and report described in paragraph (1) shall in-
clude an analysis of the impact that increased infor-
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mation sharing between Federal and State authori-
ties would have on efforts to enforce minimum 
standards on paid tax return preparers. 
(g) PUBLICATION OF COMMON ERRORS AND PEN-
ALTIES.—Not later than 36 months after the date of the 
enactment of this Act and annually thereafter, the Com-
missioner of the Internal Revenue shall publish on the 
public website of the Internal Revenue Service— 
(1) the 10 most frequent errors found on tax 
returns which were prepared by tax return preparers 
(as defined in section 7701(a)(36) of the Internal 
Revenue Code of 1986) during the preceding cal-
endar year, and 
(2) with respect to the preceding calendar year, 
the top 10 reasons that tax return preparers were— 
(A) subject to penalties imposed under the 
Internal Revenue Code of 1986, or 
(B) otherwise disciplined under section 
6109 of such Code or section 330 of title 31, 
United States Code. 
(h) RULE OF CONSTRUCTION.—Nothing in this sec-
tion (or amendment made by this section) shall be con-
strued to require the Secretary to eliminate or terminate 
any existing program or authority— 
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(1) which, pursuant to section 330 of title 31, 
United States Code, permits a tax return preparer 
to represent a taxpayer before the Department of 
the Treasury in cases in which such preparer pre-
pared and signed the return of tax, or 
(2) for publication of a public database on the 
website of the Internal Revenue Service of tax re-
turn preparers who have satisfied the requirements 
for issuance of a preparer tax identification number 
(as defined in section 6109(e)(8) of the Internal 
Revenue Code of 1986). 
(i) EFFECTIVE DATE.— 
(1) IN GENERAL.—The amendments made by 
this section shall take effect on the date which is 
180 days after the date of enactment of this Act. 
(2) TRANSITION RULES FOR EDUCATIONAL RE-
QUIREMENTS FOR TAX RETURN PREPARERS.— 
(A) ANNUAL FILING SEASON PROGRAM.— 
In the case of any tax return preparer who, as 
of the date of enactment of this Act, has re-
ceived a record of completion with respect to 
the Annual Filing Season Program established 
by the Internal Revenue Service, such tax re-
turn preparer shall be deemed to have satisfied 
the 
education 
requirements 
of 
section 
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6109(e)(3) of the Internal Revenue Code of 
1986 (as added by this section) for the calendar 
year for which such record of completion ap-
plies. 
(B) APPROVED COURSES.—In the case of 
any entity which, as of the date of enactment 
of this Act, is approved to provide continuing 
education for purposes of the Annual Filing 
Season Program established by the Internal 
Revenue Service, such entity shall be deemed to 
satisfy the applicable requirements under sec-
tion 6109(e)(3) of the Internal Revenue Code of 
1986 until the date on which the Secretary 
has— 
(i) issued such regulations or other 
guidance as the Secretary determines nec-
essary for purposes of establishing stand-
ards for educational programs under such 
section, and 
(ii) pursuant to subparagraph (E) of 
such section, published a list of educational 
programs which have been determined by 
the Secretary to satisfy the applicable re-
quirements under such section. 
Æ 
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