,,ii  #aadth ,,congress  #ast ,session  
,s4 #idi  ,,in ,,the ,,senate ,,of ,,the
 ,,united ,,states  ,april #ae1         
#bjae,mr4 ,cornyn 7for himself1 ,mr4    
,heller1 and ,mr4 ,roberts7 introduced  
the following bill2 which was read twice
 and referred to the ,committee on      
,finance  ,a ,,bill  ,to provide a      
taxpayer bill of rights for small       
businesses4  #a4 ,short title2 table of 
contents  7a7 ,short title ,this ,act   
may be cited as the ,small ,business    
,taxpayer ,bill of ,rights ,act of      
#bjae4  7b7 ,table of contents ,the     
table of contents of this ,act is as    
follows3 ,sec4 #a4 ,short title2 table  
of contents4 ,sec4 #b4 ,modification of 
standards for awarding of costs and     
certain fees4 ,sec4 #c4 ,civil damages  
allowed for reckless or intentional     
disregard of internal revenue laws4     
,sec4 #d4 ,modifications relating to    
certain offenses by officers and        
employees in connection with revenue    
laws4 ,sec4 #e4 ,modifications relating 

to civil damages for unauthorized       
inspection or disclosure of returns and 
return information4 ,sec4 #f4 ,interest 
abatement reviews4 ,sec4 #g4 ,ban on ex 
parte discussions4 ,sec4 #h4            
,alternative dispute resolution         
procedures4 ,sec4 #i4 ,extension of time
 for contesting ,,irs levy4 ,sec4 #aj4  
,waiver of installment agreement fee4   
,sec4 #aa4 ,suspension of running of    
period for filing petition of spousal   
relief and collection cases4 ,sec4 #ab4 
,venue for appeal of spousal relief and 
collection cases4 ,sec4 #ac4 ,increase  
in monetary penalties for certain       
unauthorized disclosures of information4
 ,sec4 #ad4 ,de novo tax court review of
 claims for equitable innocent spouse   
relief4 ,sec4 #ae4 ,ban on raising new  
issues on appeal4 ,sec4 #af4 ,limitation
 on enforcement of liens against        
principal residences4 ,sec4 #ag4        
,additional provisions relating to      
mandatory termination for misconduct4   
,sec4 #ah4 ,extension of declaratory    

judgment procedures to social welfare   
organizations4 ,sec4 #ai4 ,review by the
 ,treasury ,inspector ,general for ,tax 
,administration4  #b4 ,modification of  
standards for awarding of costs and     
certain fees  7a7 ,small businesses     
eligible without regard to net worth    
,subparagraph 7,d7 of section           
#gdcj7;c77#d7 of the ,internal ,revenue 
,code of #aihf is amended by striking   
and at the end of clause 7i77,,ii71 by  
striking the period at the end of clause
 7ii7 and inserting 1 and1 and by adding
 at the end the following new clause3   
7iii7 in the case of an eligible small  
business1 the net worth limitation in   
clause 7ii7 of such section shall not   
apply4  4  7b7 ,eligible small business 
,paragraph 7#d7 of section #gdcj7;c7 of 
the ,internal ,revenue ,code of #aihf is
 amended by adding at the end the       
following new subparagraph3  7,f7       
,eligible small business ,for purposes  
of subparagraph 7,d77iii71 the term     
eligible small business means1 with     

respect to any proceeding commenced in a
 taxable year--  7i7 a corporation the  
stock of which is not publicly traded1  
7ii7 a partnership1 or  7iii7 a sole    
proprietorship1  if the average annual  
gross receipts of such corporation1     
partnership1 or sole proprietorship for 
the #c-taxable-year period preceding    
such taxable year does not exceed       
#ej1jjj1jjj4 ,for purposes of applying  
the test under the preceding sentence1  
rules similar to the rules of paragraphs
 7#b7 and 7#c7 of section #ddh7;c7 shall
 apply4  4  7c7 ,effective date ,the    
amendments made by this section shall   
apply to proceedings commenced after the
 date of the enactment of this ,act4    
#c4 ,civil damages allowed for reckless 
or intentional disregard of internal    
revenue laws  7a7 ,increase in amount of
 damages ,section #gdcc7;b7 of the      
,internal ,revenue ,code of #aihf is    
amended by striking #a1jjj1jjj          
7#ajj1jjj1 in the case of negligence7   
and inserting #c1jjj1jjj 7#cjj1jjj1 in  

the case of negligence74  7b7 ,extension
 of time ,to bring action ,section      
#gdcc7;d77#c7 of the ,internal ,revenue 
,code of #aihf is amended by striking #b
 years and inserting #e years4  7c7     
,effective date ,the amendments made by 
this section shall apply to actions of  
employees of the ,internal ,revenue     
,service after the date of the enactment
 of this ,act4  #d4 ,modifications      
relating to certain offenses by officers
 and employees in connection with       
revenue laws  7a7 ,increase in penalty  
,section #gbad of the ,internal ,revenue
 ,code of #aihf is amended--  7#a7 by   
striking #aj1jjj in subsection 7a7 and  
inserting #be1jjj1 and  7#b7 by striking
 #e1jjj in subsection 7b7 and inserting 
#aj1jjj4  7b7 ,effective date ,the      
amendments made by this section shall   
take effect on the date of the enactment
 of this ,act4  #e4 ,modifications      
relating to civil damages for           
unauthorized inspection or disclosure of
 returns and return information  7a7    

,increase in amount of damages          
,subparagraph 7,a7 of section           
#gdca7;c77#a7 of the ,internal ,revenue 
,code of #aihf is amended by striking   
#a1jjj and inserting #aj1jjj4  7b7      
,effective date ,the amendment made by  
this section shall apply to inspections 
and disclosure occurring on and after   
the date of the enactment of this ,act4 
#f4 ,interest abatement reviews  7a7    
,filing period for interest abatement   
cases  7#a7 ,in general ,subsection 7h7 
of section #fdjd of the ,internal       
,revenue ,code of #aihf is amended--    
7,a7 by striking ,review of denial in   
the heading and inserting ,judicial     
review1 and  7,b7 by striking if such   
action is brought and all that follows  
in paragraph 7#a7 and inserting  if such
 action is brought-- 7,a7 at any time   
after the earlier of--  7i7 the date of 
the mailing of the ,secretary's final   
determination not to abate such         
interest1 or  7ii7 the date which is    
#ahj days after the date of the filing  

with the ,secretary 7in such form as the
 ,secretary may prescribe7 of a claim   
for abatement under this section1 and   
7,b7 not later than the date which is   
#ahj days after the date described in   
subparagraph 7,a77i74  4  7#b7          
,effective date ,the amendments made by 
this subsection shall apply to claims   
for abatement of interest filed with the
 ,secretary after the date of the       
enactment of this ,act4  7b7 ,small tax 
case election for interest abatement    
cases  7#a7 ,in general ,subsection 7f7 
of section #gdfc of the ,internal       
,revenue ,code of #aihf is amended--    
7,a7 by striking and at the end of      
paragraph 7#a71  7,b7 by striking the   
period at the end of paragraph 7#b7 and 
inserting 1 and1 and  7,c7 by adding at 
the end the following new paragraph3    
7#c7 a petition to the ,tax court under 
section #fdjd7;h7 in which the amount of
 interest abatement sought does not     
exceed #ej1jjj4  4  7#b7 ,effective date
 ,the amendments made by this subsection

 shall apply to--  7,a7 cases pending as
 of the day after the date of the       
enactment of this ,act1 and  7,b7 cases 
commenced after such date of enactment4 
#g4 ,ban on ex parte discussions  7a7   
,in general ,notwithstanding section    
#ajja7;a77#d7 of the ,internal ,revenue 
,service ,restructuring and ,reform ,act
 of #aiih1 the ,internal ,revenue       
,service shall prohibit any ex parte    
communications between officers in the  
,internal ,revenue ,service ,office of  
,appeals and other ,internal ,revenue   
,service employees with respect to any  
matter pending before such officers4    
7b7 ,termination of employment for      
misconduct ,subject to subsection 7c71  
the ,commissioner of ,internal ,revenue 
shall terminate the employment of any   
employee of the ,internal ,revenue      
,service if there is a final            
administrative or judicial determination
 that such employee committed any act or
 omission prohibited under subsection   
7a7 in the performance of the employee's

 official duties4 ,such termination     
shall be a removal for cause on charges 
of misconduct4  7c7 ,determination of   
commissioner  7#a7 ,in general ,the     
,commissioner of ,internal ,revenue may 
take a personnel action other than      
termination for an act prohibited under 
subsection 7a74  7#b7 ,discretion ,the  
exercise of authority under paragraph   
7#a7 shall be at the sole discretion of 
the ,commissioner of ,internal ,revenue 
and may not be delegated to any other   
officer4 ,at the sole discretion of the 
,commissioner of ,internal ,revenue1    
such ,commissioner may establish a      
procedure which will be used to         
determine whether an individual should  
be referred to the ,commissioner of     
,internal ,revenue for a determination  
by the ,commissioner under paragraph    
7#a74  7#c7 ,no appeal ,any             
determination of the ,commissioner of   
,internal ,revenue under this subsection
 may not be appealed in any             
administrative or judicial proceeding4  

7d7 ,,tigta reporting of termination or 
mitigation ,section #ghjc7;d77#a77;,e7  
of the ,internal ,revenue ,code of #aihf
 is amended by inserting or section #g  
of the ,small ,business ,taxpayer ,bill 
of ,rights ,act of #bjae after #aiih4   
#h4 ,alternative dispute resolution     
procedures  7a7 ,in general ,section    
#gabc of the ,internal ,revenue ,code of
 #aihf is amended by adding at the end  
the following new subsection3  7c7      
,availability of dispute resolutions    
7#a7 ,in general ,the procedures        
prescribed under subsection 7b77#a7 and 
the pilot program established under     
subsection 7b77#b7 shall provide that a 
taxpayer may request mediation or       
arbitration in any case unless the      
,secretary has specifically excluded the
 type of issue involved in such case or 
the class of cases to which such case   
belongs as not appropriate for          
resolution under such subsection4 ,the  
,secretary shall make any determination 
that excludes a type of issue or a class

 of cases public within #e working days 
and provide an explanation for each     
determination4  7#b7 ,independent       
mediators  7,a7 ,in general ,the        
procedures prescribed under subsection  
7b77#a7 shall provide the taxpayer an   
opportunity to elect to have the        
mediation conducted by an independent1  
neutral individual not employed by the  
,internal ,revenue ,service ,office of  
,appeals4  7,b7 ,cost and selection  7i7
 ,in general ,any taxpayer making an    
election under subparagraph 7,a7 shall  
be required--  7,i7 to share the costs  
of such independent mediator equally    
with the ,internal ,revenue ,service    
,office of ,appeals1 and  7,,ii7 to     
limit the selection of the mediator to a
 roster of recognized national or local 
neutral mediators4  7ii7 ,exception     
,clause 7i77,i7 shall not apply to any  
taxpayer who is an individual or who was
 a small business in the preceding      
calendar year if such taxpayer had an   
adjusted gross income that did not      

exceed #bej percent of the poverty      
level1 as determined in accordance with 
criteria established by the ,director of
 the ,office of ,management and ,budget1
 in the taxable year preceding the      
request4  7iii7 ,small business ,for    
purposes of clause 7ii71 the term small 
business has the meaning given such term
 under section #da7;b77#c77;,d77iii74   
7#c7 ,availability of process ,the      
procedures prescribed under subsection  
7b77#a7 and the pilot program           
established under subsection 7b77#b7    
shall provide the opportunity to elect  
mediation or arbitration at the time    
when the case is first filed with the   
,office of ,appeals and at any time     
before deliberations in the appeal      
commence4  4  7b7 ,effective date ,the  
amendment made by this section shall    
take effect on the date of the enactment
 of this ,act4  #i4 ,extension of time  
for contesting ,,irs levy  7a7          
,extension of time for return of        
property subject to levy ,subsection 7b7

 of section #fcdc of the ,internal      
,revenue ,code of #aihf is amended by   
striking #i months and inserting #c     
years4  7b7 ,period of limitation on    
suits ,subsection 7c7 of section #fecb  
of the ,internal ,revenue ,code of #aihf
 is amended--  7#a7 in paragraph 7#a7 by
 striking #i months and inserting #c    
years1 and  7#b7 in paragraph 7#b7 by   
striking #i-month and inserting #c-year4
  7c7 ,effective date ,the amendments   
made by this section shall apply to--   
7#a7 levies made after the date of the  
enactment of this ,act1 and  7#b7 levies
 made on or before such date if the     
#i-month period under section #fcdc7;b7 
of the ,internal ,revenue ,code of #aihf
 7without regard to this section7 has   
not expired as of such date4  #aj4      
,waiver of installment agreement fee    
7a7 ,in general ,section #faei of the   
,internal ,revenue ,code of #aihf is    
amended by redesignating subsection 7f7 
as subsection 7g7 and by inserting after
 subsection 7e7 the following new       

subsection3  7f7 ,waiver of installment 
agreement fee ,the ,secretary shall     
waive the fees imposed on installment   
agreements under this section for any   
taxpayer with an adjusted gross income  
that does not exceed #bej percent of the
 poverty level1 as determined in        
accordance with criteria established by 
the ,director of the ,office of         
,management and ,budget1 and who has    
agreed to make payments under the       
installment agreement by electronic     
payment through a debit instrument4  4  
7b7 ,effective date ,the amendment made 
by this section shall take effect on the
 date of the enactment of this ,act4    
#aa4 ,suspension of running of period   
for filing petition of spousal relief   
and collection cases  7a7 ,petitions for
 spousal relief  7#a7 ,in general       
,subsection 7e7 of section #fjae of the 
,internal ,revenue ,code of #aihf is    
amended by adding at the end the        
following new paragraph3  7#f7          
,suspension of running of period for    

filing petition in title #aa cases ,in  
the case of a person who is prohibited  
by reason of a case under title #aa1    
,united ,states ,code1 from filing a    
petition under paragraph 7#a77;,a7 with 
respect to a final determination of     
relief under this section1 the running  
of the period prescribed by such        
paragraph for filing such a petition    
with respect to such final determination
 shall be suspended for the period      
during which the person is so prohibited
 from filing such a petition1 and for   
#fj days thereafter4  4  7#b7 ,effective
 date ,the amendment made by this       
subsection shall apply to petitions     
filed under section #fjae7;e7 of the    
,internal ,revenue ,code of #aihf after 
the date of the enactment of this ,act4 
7b7 ,collection proceedings  7#a7 ,in   
general ,subsection 7d7 of section #fccj
 of the ,internal ,revenue ,code of     
#aihf is amended--  7,a7 by striking    
appeal such determination to the ,tax   
,court in paragraph 7#a7 and inserting  

petition the ,tax ,court for review of  
such determination1  7,b7 by striking   
,judicial review of determination in the
 heading of paragraph 7#a7 and inserting
 ,petition for review by ,tax ,court1   
7,c7 by redesignating paragraph 7#b7 as 
paragraph 7#c71 and  7,d7 by inserting  
after paragraph 7#a7 the following new  
paragraph3  7#b7 ,suspension of running 
of period for filing petition in title  
#aa cases ,in the case of a person who  
is prohibited by reason of a case under 
title #aa1 ,united ,states ,code1 from  
filing a petition under paragraph 7#a7  
with respect to a determination under   
this section1 the running of the period 
prescribed by such subsection for filing
 such a petition with respect to such   
determination shall be suspended for the
 period during which the person is so   
prohibited from filing such a petition1 
and for #cj days thereafter4  4  7#b7   
,conforming amendment ,subsection 7c7 of
 section #fcbj of such ,code is amended 
by striking 7#b77;,b7 and inserting     

7#c77;,b74  7#c7 ,effective date ,the   
amendments made by this subsection shall
 apply to petitions filed under section 
#fccj of the ,internal ,revenue ,code of
 #aihf after the date of the enactment  
of this ,act4  #ab4 ,venue for appeal of
 spousal relief and collection cases    
7a7 ,in general ,paragraph 7#a7 of      
section #gdhb7;b7 of the ,internal      
,revenue ,code of #aihf is amended--    
7#a7 by striking or at the end of       
subparagraph 7,e71  7#b7 by striking the
 period at the end of subparagraph      
7,f77ii7 and inserting a comma1 and     
7#c7 by inserting after subparagraph    
7,f7 the following new subparagraphs3   
7,g7 in the case of a petition under    
section #fjae7;e71 the legal residence  
of the petitioner1 or  7,h7 in the case 
of a petition under section #fcbj or    
#fccj--  7i7 the legal residence of the 
petitioner if the petitioner is an      
individual1 and  7ii7 the principal     
place of business or principal office or
 agency if the petitioner is an entity  

other than an individual4  4  7b7       
,effective date ,the amendments made by 
this section shall apply to petitions   
filed after the date of enactment of    
this ,act4  #ac4 ,increase in monetary  
penalties for certain unauthorized      
disclosures of information  7a7 ,in     
general ,paragraphs 7#a71 7#b71 7#c71   
and 7#d7 of section #gbac7;a7 of the    
,internal ,revenue ,code of #aihf are   
each amended by striking #e1jjj and     
inserting #aj1jjj4  7b7 ,effective date 
,the amendments made by this section    
shall apply to disclosures made after   
the date of the enactment of this ,act4 
#ad4 ,de novo tax court review of claims
 for equitable innocent spouse relief   
7a7 ,in general ,subparagraph 7,a7 of   
section #fjae7;e77#a7 of the ,internal  
,revenue ,code of #aihf is amended by   
adding at the end the following new     
flush sentence3  ,any review of a       
determination by the ,secretary with    
respect to a claim for equitable relief 
under subsection 7f7 shall be reviewed  

de novo by the ,tax ,court4 4  7b7      
,effective date ,the amendment made by  
this section shall apply to petitions   
filed or pending before the ,tax ,court 
on and after the date of the enactment  
of this ,act4  #ae4 ,ban on raising new 
issues on appeal  7a7 ,in general       
,chapter #gg of the ,internal ,revenue  
,code of #aihf is amended by adding at  
the end the following new section3      
#gebi4 ,prohibition on ,internal        
,revenue ,service raising new issues in 
an internal appeal  7a7 ,in general ,in 
reviewing an appeal of any determination
 initially made by the ,internal        
,revenue ,service1 the ,internal        
,revenue ,service ,office of ,appeals   
may not consider or decide any issue    
that is not within the scope of the     
initial determination4  7b7 ,certain    
issues deemed outside of scope of       
determination ,for purposes of          
subsection 7a71 the following matters   
shall be considered to be not within the
 scope of a determination3  7#a7 ,any   

issue that was not raised in a notice of
 deficiency or an examiner's report     
which is the subject of the appeal4     
7#b7 ,any deficiency in tax which was   
not included in the initial             
determination4  7#c7 ,any theory or     
justification for a tax deficiency which
 was not considered in the initial      
determination4  7c7 ,no inference with  
respect to issues raised by taxpayers   
,nothing in this section shall be       
construed to provide any limitation in  
addition to any limitations in effect on
 the date of the enactment of this      
section on the right of a taxpayer to   
raise an issue1 theory1 or justification
 on an appeal from a determination      
initially made by the ,internal ,revenue
 ,service that was not within the scope 
of the initial determination4  4  7b7   
,clerical amendment ,the table of       
sections for chapter #gg of such ,code  
is amended by adding at the end the     
following new item3  ,sec4 #gebi4       
,prohibition on ,internal ,revenue      

,service raising new issues in an       
internal appeal4  4  7c7 ,effective date
 ,the amendments made by this section   
shall apply to matters filed or pending 
with the ,internal ,revenue ,service    
,office of ,appeals on or after the date
 of the enactment of this ,act4  #af4   
,limitation on enforcement of liens     
against principal residences  7a7 ,in   
general ,section #gdjc7;a7 of the       
,internal ,revenue ,code of #aihf is    
amended--  7#a7 by striking ,in any case
 and inserting the following3  7#a7 ,in 
general ,in any case  1 and  7#b7 by    
adding at the end the following new     
paragraph3  7#b7 ,limitation with       
respect to principal residence  7,a7 ,in
 general ,paragraph 7#a7 shall not apply
 to any property used as the principal  
residence of the taxpayer 7within the   
meaning of section #aba7 unless the     
,secretary of the ,treasury makes a     
written determination that--  7i7 all   
other property of the taxpayer1 if sold1
 is insufficient to pay the tax or      

discharge the liability1 and  7ii7 such 
action will not create an economic      
hardship for the taxpayer4  7,b7        
,delegation ,for purposes of this       
paragraph1 the ,secretary of the        
,treasury may not delegate any          
responsibilities under subparagraph 7,a7
 to any person other than--  7i7 the    
,commissioner of ,internal ,revenue1 or 
7ii7 a district director or assistant   
district director of the ,internal      
,revenue ,service4  4  7b7 ,effective   
date ,the amendments made by this       
section shall apply to actions filed    
after the date of the enactment of this 
,act4  #ag4 ,additional provisions      
relating to mandatory termination for   
misconduct  7a7 ,termination of         
unemployment for inappropriate review of
 tax-,exempt status ,section #abjc7;b7  
of the ,internal ,revenue ,service      
,restructuring and ,reform ,act of #aiih
 7#bf ,u4,s4,c4 #ghjd note7 is amended  
by striking and at the end of paragraph 
7#i71 by striking the period at the end 

of paragraph 7#aj7 and inserting 2 and1 
and by adding at the end the following  
new paragraph3  7#aa7 in the case of any
 review of an application for tax-exempt
 status by an organization described in 
section #eja7;c7 of the ,internal       
,revenue ,code of #aihf1 developing or  
using any methodology that applies      
disproportionate scrutiny to any        
applicant based on the ideology         
expressed in the name or purpose of the 
organization4  4  7b7 ,mandatory unpaid 
administrative leave for misconduct     
,paragraph 7#a7 of ,section #abjc7;c7 of
 the ,internal ,revenue ,service        
,restructuring and ,reform ,act of #aiih
 7#bf ,u4,s4,c4 #ghjd note7 is amended  
by adding at the end the following new  
sentence3 ,notwithstanding the preceding
 sentence1 if the ,commissioner of      
,internal ,revenue takes a personnel    
action other than termination for an act
 or omission described in subsection    
7b71 the ,commissioner shall place the  
employee on unpaid administrative leave 

for a period of not less than #cj days44
  7c7 ,limitation on alternative        
punishment ,paragraph 7#a7 of section   
#abjc7;c7 of the ,internal ,revenue     
,service ,restructuring and ,reform ,act
 of #aiih 7#bf ,u4,s4,c4 #ghjd note7 is 
amended by striking ,the ,commissioner  
and inserting ,except in the case of an 
act or omission described in subsection 
7b77#c77;,a71 the ,commissioner4  #ah4  
,extension of declaratory judgment      
procedures to social welfare            
organizations  7a7 ,in general ,section 
#gdbh7;a77#a7 of the ,internal ,revenue 
,code of #aihf is amended by striking or
 at the end of subparagraph 7,c7 and by 
adding at the end the following new     
subparagraph3  7,e7 with respect to the 
initial classification or continuing    
classification of an organization       
described in section #eja7;c77#d7 which 
is exempt from tax under section        
#eja7;a71 or  4  7b7 ,effective date    
,the amendments made by this section    
shall apply with respect to pleading    

filed after the date of the enactment of
 this ,act4  #ai4 ,review by the        
,treasury ,inspector ,general for ,tax  
,administration  7a7 ,review ,subsection
 7k77#a7 of section #h;,d of the        
,inspector ,general ,act of #aigh 7#e   
,u4,s4,c4 ,app47 is amended--  7#a7 in  
subparagraph 7,c71 by striking and at   
the end2  7#b7 by redesignating         
subparagraph 7,d7 as subparagraph 7,e72 
7#c7 by inserting after subparagraph    
7,c7 the following new subparagraph3    
7,d7 shall-- 7i7 review any criteria    
employed by the ,internal ,revenue      
,service to select tax returns          
7including applications for recognition 
of tax-exempt status7 for examination or
 audit1 assessment or collection of     
deficiencies1 criminal investigation or 
referral1 refunds for amounts paid1 or  
any heightened scrutiny or review in    
order to determine whether the criteria 
discriminates against taxpayers on the  
basis of race1 religion1 or political   
ideology2 and  7ii7 consult with the    

,internal ,revenue ,service on          
recommended amendments to such criteria 
in order to eliminate any discrimination
 identified pursuant to the review      
described in clause 7i72 and  2 and     
7#d7 in subparagraph 7,e71 as so        
redesignated1 by striking and 7,c7 and  
inserting 7,c71 and 7,d74  7b7          
,semiannual ,report ,subsection 7g7 of  
such section is amended by adding at the
 end the following new paragraph3  7#c7 
,any semiannual report made by the      
,treasury ,inspector ,general for ,tax  
,administration that is required        
pursuant to section #e7;a7 shall        
include--  7,a7 a statement affirming   
that the ,treasury ,inspector ,general  
for ,tax ,administration has reviewed   
the criteria described in subsection    
7k77#a77;,d7 and consulted with the     
,internal ,revenue ,service regarding   
such criteria2 and  7,b7 a description  
and explanation of any such criteria    
that was identified as discriminatory by
 the ,treasury ,inspector ,general for  

,tax ,administration4  4