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 an ownership interest in prop-
erty seized pursuant to subparagraph (A) 
by 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 
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law or regulation other than section 
5324.’’. 
SEC. 1202. 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: 
‘‘SEC. 139H. 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. 139H. Interest received in action to recover property seized by the Inter-
nal Revenue Service based on structuring transaction.’’. 
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(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. 1203. 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 
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 
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‘‘(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-
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. 1204. 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-
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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 
that is 45 days after the date of the enactment of this 
Act. 
SEC. 1205. PRIVATE DEBT COLLECTION AND SPECIAL COM-
PLIANCE PERSONNEL PROGRAM. 
(a) CERTAIN TAX RECEIVABLES NOT ELIGIBLE FOR 
COLLECTION UNDER TAX COLLECTION CONTRACTS.— 
Section 6306(d)(3) is amended by striking ‘‘or’’ at the end 
of subparagraph (C) and by inserting after subparagraph 
(D) the following new subparagraphs: 
‘‘(E) a taxpayer substantially all of whose 
income consists of disability insurance benefits 
under section 223 of the Social Security Act or 
supplemental security income benefits under 
title XVI of the Social Security Act (including 
supplemental security income benefits of the 
type described in section 1616 of such Act or 
section 212 of Public Law 93–66), or 
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‘‘(F) 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 200 
percent of the applicable poverty level (as deter-
mined by the Secretary),’’. 
(b) DETERMINATION
OF INACTIVE TAX RECEIV-
ABLES ELIGIBLE FOR COLLECTION UNDER TAX COLLEC-
TION CONTRACTS.—Section 6306(c)(2)(A)(ii) is amended 
by striking ‘‘more than 1⁄3 of the period of the applicable 
statute of limitation has lapsed’’ and inserting ‘‘more than 
2 years has passed since assessment’’. 
(c) MAXIMUM LENGTH OF INSTALLMENT AGREE-
MENTS
OFFERED
UNDER
TAX
COLLECTION
CON-
TRACTS.—Section 6306(b)(1)(B) is amended by striking 
‘‘5 years’’ and inserting ‘‘7 years’’. 
(d) CLARIFICATION THAT SPECIAL COMPLIANCE 
PERSONNEL PROGRAM ACCOUNT MAY BE USED
FOR 
PROGRAM COSTS.— 
(1) IN GENERAL.—Section 6307(b) is amend-
ed— 
(A) in paragraph (2), by striking all that 
follows ‘‘under such program’’ and inserting a 
period, and 
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(B) in paragraph (3), by striking all that 
follows ‘‘out of such account’’ and inserting 
‘‘for other than program costs.’’. 
(2) COMMUNICATIONS, SOFTWARE, AND TECH-
NOLOGY COSTS TREATED AS PROGRAM COSTS.—Sec-
tion 6307(d)(2)(B) is amended by striking ‘‘tele-
communications’’ and inserting ‘‘communications, 
software, technology’’. 
(3) 
CONFORMING
AMENDMENT.—Section 
6307(d)(2) is amended by striking ‘‘and’’ at the end 
of subparagraph (A), by striking the period at the 
end of subparagraph (B) and inserting ‘‘, and’’, and 
by inserting after subparagraph (B) the following 
new subparagraph: 
‘‘(C) reimbursement of the Internal Rev-
enue Service or other government agencies for 
the cost of administering the qualified tax col-
lection program under section 6306.’’. 
(e) EFFECTIVE DATES.— 
(1) IN
GENERAL.—Except as otherwise pro-
vided in this subsection, the amendments made by 
this section shall apply to tax receivables identified 
by the Secretary (or the Secretary’s delegate) after 
December 31, 2020. 
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(2) 
MAXIMUM
LENGTH
OF
INSTALLMENT 
AGREEMENTS.—The amendment made by subsection 
(c) shall apply to contracts entered into after the 
date of the enactment of this Act. 
(3) USE OF SPECIAL COMPLIANCE PERSONNEL 
PROGRAM ACCOUNT.—The amendment made by sub-
section (d) shall apply to amounts expended from 
the special compliance personnel program account 
after the date of the enactment of this Act. 
SEC. 1206. REFORM OF NOTICE OF CONTACT OF THIRD 
PARTIES. 
(a) IN GENERAL.—Section 7602(c)(1) is amended to 
read as follows: 
‘‘(1) GENERAL
NOTICE.—An officer or em-
ployee of the Internal Revenue Service may not con-
tact any person other than the taxpayer with respect 
to the determination or collection of the tax liability 
of such taxpayer unless such contact occurs during 
a period (not greater than 1 year) which is specified 
in a notice which— 
‘‘(A) informs the taxpayer that contacts 
with persons other than the taxpayer are in-
tended to be made during such period, and 
‘‘(B) except as otherwise provided by the 
Secretary, is provided to the taxpayer not later 
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than 45 days before the beginning of such pe-
riod. 
Nothing in the preceding sentence shall prevent the 
issuance of notices to the same taxpayer with respect 
to the same tax liability with periods specified there-
in that, in the aggregate, exceed 1 year. A notice 
shall not be issued under this paragraph unless 
there is an intent at the time such notice is issued 
to contact persons other than the taxpayer during 
the period specified in such notice. The preceding 
sentence shall not prevent the issuance of a notice 
if the requirement of such sentence is met on the 
basis of the assumption that the information sought 
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. 1207. MODIFICATION OF AUTHORITY TO ISSUE DES-
IGNATED SUMMONS. 
(a) IN GENERAL.—Paragraph (1) of section 6503(j) 
is amended by striking ‘‘coordinated examination pro-
gram’’ and inserting ‘‘coordinated industry case pro-
gram’’. 
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(b) REQUIREMENTS FOR SUMMONS.—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 Commissioner 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,’’. 
(c) ESTABLISHMENT THAT REASONABLE REQUESTS 
FOR INFORMATION WERE MADE.—Subsection (j) of sec-
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.’’. 
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‘‘(D) which uses a quality review process 
which reviews 100 percent of all returns. 
‘‘(2) QUALIFIED ENTITY.— 
‘‘(A) IN
GENERAL.—The term ‘qualified 
entity’ means any entity which— 
‘‘(i) is an eligible organization, 
‘‘(ii) is in compliance with Federal tax 
filing and payment requirements, 
‘‘(iii) is not debarred or suspended 
from Federal contracts, grants, or coopera-
tive agreements, and 
‘‘(iv) agrees to provide documentation 
to substantiate any matching funds pro-
vided pursuant to the grant program under 
this section. 
‘‘(B) ELIGIBLE ORGANIZATION.—The term 
‘eligible organization’ means— 
‘‘(i) an institution of higher education 
which is described in section 102 (other 
than subsection (a)(1)(C) thereof) of the 
Higher Education Act of 1965 (20 U.S.C. 
1002), as in effect on the date of the en-
actment of this section, and which has not 
been disqualified from participating in a 
program under title IV of such Act, 
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