,,ib ,union ,calendar ,no4 #dhh #aaeth ,,congress #b;d ,session ,h4 ,r4 #eddd ,report ,no4 #aae-fcg1 ,part ,i ,,in ,,the ,,house ,,of ,,representatives ,april #aj1 #bjah ,ms4 ,jenkins of ,kansas 7for herself and ,mr4 ,lewis of ,georgia7 introduced the following bill2 which was referred to the ,committee on ,ways and ,means1 and in addition to the ,committee on ,financial ,services1 for a period to be subsequently determined by the ,speaker1 in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned ,april #ac1 #bjah;,additional sponsors3 ,mr4 ,mc,govern1 ,mr4 ,sessions1 and ,mr4 ,marchant ,april #ac1 #bjah ,reported from the ,committee on ,ways and ,means with an amendment ,strike out all after the enacting clause and insert the part printed in italic ,april #ac1 #bjah,the ,committee on ,financial ,services discharged2 committed to the ,committee of the ,whole ,house on the ,state of the ,union and ordered to be printed,for text of introduced bill1 see copy of bill as introduced on ,april #aj1 #bjah ,a ,,bill ,to amend the ,internal ,revenue ,code of #aihf to modernize and improve the ,internal ,revenue ,service1 and for other purposes4 #a4 ,short title2 etc 7a7 ,short title ,this ,act may be cited as the ,taxpayer ,first ,act4 7b7 ,amendment of #aihf ,code ,except as otherwise expressly provided1 whenever in this ,act an amendment or repeal is expressed in terms of an amendment to1 or repeal of1 a section or other provision1 the reference shall be considered to be made to a section or other provision of the ,internal ,revenue ,code of #aihf4 7c7 ,table of contents ,the table of contents of this ,act is as follows3 ,sec4 #a4 ,short title2 etc4 ,title ,i--,independent appeals process ,sec4 #aja4 ,establishment of ,internal ,revenue ,service ,independent ,office of ,appeals4 ,title ,,ii--,improved ,service ,sec4 #bja4 ,comprehensive customer service strategy4 ,sec4 #bjb4 ,,irs ,free ,file ,program4 ,sec4 #bjc4 ,low-income exception for payments otherwise required in connection with a submission of an offer-in-compromise4 ,title ,,iii--,sensible ,enforcement ,sec4 #cja4 ,internal ,revenue ,service seizure requirements with respect to structuring transactions4 ,sec4 #cjb4 ,exclusion of interest received in action to recover property seized by the ,internal ,revenue ,service based on structuring transaction4 ,sec4 #cjc4 ,clarification of equitable relief from joint liability4 ,sec4 #cjd4 ,modification of procedures for issuance of third-party summons4 ,sec4 #cje4 ,establishment of income threshold for referral to private debt collection4 ,sec4 #cjf4 ,reform of notice of contact of third parties4 ,sec4 #cjg4 ,modification of authority to issue designated summons4 ,sec4 #cjh4 ,limitation on access of non-,internal ,revenue ,service employees to returns and return information4 ,title ,,iv--,organizational modernization ,sec4 #dja4 ,modification of title of ,commissioner of ,internal ,revenue and related officials4 ,sec4 #djb4 ,office of the ,national ,taxpayer ,advocate4 ,sec4 #djc4 ,elimination of ,,irs ,oversight ,board4 ,sec4 #djd4 ,modernization of ,internal ,revenue ,service organizational structure4 ,title ,v--,tax ,court ,sec4 #eja4 ,disqualification of judge or magistrate judge of the ,tax ,court4 ,sec4 #ejb4 ,opinions and judgments4 ,sec4 #ejc4 ,title of special trial judge changed to magistrate judge of the ,tax ,court4 ,sec4 #ejd4 ,repeal of deadwood related to ,board of ,tax ,appeals4 ,i ,independent appeals process #aja4 ,establishment of ,internal ,revenue ,service ,independent ,office of ,appeals 7a7 ,in general ,section #ghjc is amended by adding at the end the following new subsection3 7e7 ,independent ,office of ,appeals 7#a7 ,establishment ,there is established in the ,internal ,revenue ,service an office to be known as the ,internal ,revenue ,service ,independent ,office of ,appeals4 7#b7 ,chief of ,appeals 7,a7 ,in general ,the ,internal ,revenue ,service ,independent ,office of ,appeals shall be under the supervision and direction of an official to be known as the ,chief of ,appeals4 ,the ,chief of ,appeals shall report directly to the ,administrator 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 #echb of title #e1 ,united ,states ,code4 7,b7 ,appointment ,the ,chief of ,appeals shall be appointed by the ,administrator of the ,internal ,revenue ,service without regard to the provisions of title #e1 ,united ,states ,code1 relating to appointments in the competitive service or the ,senior ,executive ,service4 7,c7 ,qualifications ,an individual appointed under subparagraph 7,b7 shall have experience and expertise in-- 7i7 administration of1 and compliance with1 ,federal tax laws1 7ii7 a broad range of compliance cases1 and 7iii7 management of large service organizations4 7#c7 ,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-- 7,a7 is fair and impartial to both the ,government and the taxpayer1 7,b7 promotes a consistent application and interpretation of1 and voluntary compliance with1 the ,federal tax laws1 and 7,c7 enhances public confidence in the integrity and efficiency of the ,internal ,revenue ,service4 7#d7 ,right of appeal ,the resolution process described in paragraph 7#c7 shall be generally available to all taxpayers4 7#e7 ,limitation on designation of cases as not eligible for referral to ,independent ,office of ,appeals 7,a7 ,in general ,if any taxpayer which is in receipt of notice of deficiency authorized under section #fbab requests referral to the ,internal ,revenue ,service ,independent ,office of ,appeals and such request is denied1 the ,administrator of the ,internal ,revenue ,service shall provide such taxpayer a written notice which-- 7i7 provides a detailed description of the facts involved1 the basis for the decision to deny the request1 and a detailed explanation of how the basis of such decision applies to such facts1 and 7ii7 describes the procedures proscribed under subparagraph 7,c7 for protesting the decision to deny the request4 7,b7 ,report to ,congress ,the ,administrator of the ,internal ,revenue ,service shall submit a written report to ,congress on an annual basis which includes the number of requests described in subparagraph 7,a7 which were denied and the reasons 7described by category7 that such requests were denied4 7,c7 ,procedures for protesting denial of request ,the ,administrator of the ,internal ,revenue ,service shall prescribe procedures for protesting to the ,administrator of the ,internal ,revenue ,service 7personally and not through any delegate7 a denial of a request described in subparagraph 7,a74 7,d7 ,not applicable to frivolous positions ,this paragraph shall not apply to a request for referral to the ,internal ,revenue ,service ,independent ,office of ,appeals which is denied on the basis that the issue involved is a frivolous position 7within the meaning of section #fgjb7;c774 7#f7 ,staff 7,a7 ,in general ,all personnel in the ,internal ,revenue ,service ,independent ,office of ,appeals shall report to the ,chief of ,appeals4 7,b7 ,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 ,counsel4 ,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 who are not involved in preparing such case for litigation4 7#g7 ,access to case files 7,a7 ,in general ,in the case of any specified taxpayer with respect to which a conference with the ,internal ,revenue ,service ,independent ,office of ,appeals has been scheduled1 the ,chief of ,appeals shall ensure that such taxpayer is provided access to the nonprivileged portions of the case file on record regarding the disputed issues 7other than documents provided by the taxpayer to the ,internal ,revenue ,service7 not later than #aj days before the date of such conference4 7,b7 ,taxpayer election to expedite conference ,if the taxpayer so elects1 subparagraph 7,a7 shall be applied by substituting the date of such conference for #aj days before the date of such conference4 7,c7 ,specified taxpayer ,for purposes of this paragraph-- 7i7 ,in general ,the term specified taxpayer means-- 7,i7 in the case of any taxpayer who is a natural person1 a taxpayer whose adjusted gross income does not exceed #djj1jjj1 and 7,,ii7 in the case of any other taxpayer1 a taxpayer whose gross receipts do not exceed #e1jjj1jjj4 7ii7 ,aggregation rule ,rules similar to the rules of section #ddh7;c77#b7 shall apply for purposes of clause 7i77,,ii74 4 7b7 ,conforming amendments 7#a7 ,the following provisions are each amended by striking ,internal ,revenue ,service ,office of ,appeals and inserting ,internal ,revenue ,service ,independent ,office of ,appeals3 7,a7 ,section #fjae7;c77#d77;,b77ii77,i74 7,b7 ,section #fcbj7;b77#a74 7,c7 ,subsections 7b77#a7 and 7d77#c7 of section #fccj4 7,d7 ,section #ffjc7;d77#c77;,b74 7,e7 ,section #ffba7;c77#b77;,a77i74 7,f7 ,section #gabb7;e77#b74 7,g7 ,subsections 7a71 7b77#a71 7b77#b71 and 7c77#a7 of section #gabc4 7,h7 ,subsections 7c77#g77;,b77i1 and 7g77#b77;,a7 of section #gdcj4 7,i7 ,section #gebb7;b77#c74 7,j7 ,section #gfab7;c77#b77;,a74 7#b7 ,section #gdcj7;c77#b7 is amended by striking ,internal ,revenue ,service ,office of ,appeals each place it appears and inserting ,internal ,revenue ,service ,independent ,office of ,appeals4 7#c7 ,the heading of section #fccj7;d77#c7 is amended by inserting ,independent after ,,irs4 7c7 ,other references ,any reference in any provision of law1 or regulation or other guidance1 to the ,internal ,revenue ,service ,office of ,appeals shall be treated as a reference to the ,internal ,revenue ,service ,independent ,office of ,appeals4 7d7 ,savings provisions ,rules similar to the rules of paragraphs 7#b7 through 7#f7 of section #ajja7;b7 of the ,internal ,revenue ,service ,restructuring and ,reform ,act of #aiih shall apply for purposes of this section 7and the amendments made by this section74 7e7 ,effective date 7#a7 ,in general ,except as otherwise provided in this subsection1 the amendments made by this section shall take effect on the date of the enactment of this ,act4 7#b7 ,access to case files ,section #ghjc7;e77#g7 of the ,internal ,revenue ,code of #aihf1 as added by subsection 7a71 shall apply to conferences occurring after the date which is #a year after the date of the enactment of this ,act4 ,,ii ,improved ,service #bja4 ,comprehensive customer service strategy 7a7 ,in general ,not later than the date which is #a year after the date of the enactment of this ,act1 the ,secretary of the ,treasury1 after consultation with the ,national ,taxpayer ,advocate1 shall submit to ,congress a written comprehensive customer service strategy for the ,internal ,revenue ,service4 ,such strategy shall include-- 7#a7 a plan to provide assistance to taxpayers that is secure1 designed to meet reasonable taxpayer expectations1 and adopts appropriate best practices of customer service provided in the private sector1 including online services1 telephone call back services1 and training of employees providing customer services1 7#b7 a thorough assessment of the services that the ,internal ,revenue ,service can co-locate with other ,federal services or offer as self-service options1 7#c7 proposals to improve ,internal ,revenue ,service customer service in the short term 7the current and following fiscal year71 medium term 7approximately #c to #e fiscal years71 and long term 7approximately #aj fiscal years71 7#d7 a plan to update guidance and training materials for customer service employees of the ,internal ,revenue ,service1 including the ,internal ,revenue ,manual1 to reflect such strategy1 and 7#e7 identified metrics and benchmarks for quantitatively measuring the progress of the ,internal ,revenue ,service in implementing such strategy4 7b7 ,updated guidance and training materials ,not later than #b years after the date of the enactment of this ,act1 the ,secretary of the ,treasury shall make available the updated guidance and training materials described in subsection 7a77#d7 7including the ,internal ,revenue ,manual74 ,such updated guidance and training materials 7including the ,internal ,revenue ,manual7 shall be written in a manner so as to be easily understood by customer service employees of the ,internal ,revenue ,service and shall provide clear instructions4 #bjb4 ,,irs ,free ,file ,program 7a7 ,in general 7#a7 ,the ,secretary of the ,treasury1 or the ,secretary's delegate1 shall continue to operate the ,,irs ,free ,file ,program as established by the ,internal ,revenue ,service and published in the ,federal ,register on ,november #d1 #bjjb 7#fg ,fed4 ,reg4 #fgbdg71 including any subsequent agreements and governing rules established pursuant thereto4 7#b7 ,the ,,irs ,free ,file ,program shall continue to provide free commercial-type online individual income tax preparation and electronic filing services to the lowest #gj percent of taxpayers by adjusted gross income4 ,the number of taxpayers eligible to receive such services each year shall be calculated by the ,internal ,revenue ,service annually based on prior year aggregate taxpayer adjusted gross income data4 7#c7 ,in addition to the services described in paragraph 7#b71 and in the same manner1 the ,,irs ,free ,file ,program shall continue to make available to all taxpayers 7without regard to income7 a basic1 online electronic fillable forms utility4 7#d7 ,the ,,irs ,free ,file ,program shall continue to work cooperatively with the private sector to provide the free individual income tax preparation and the electronic filing services described in paragraphs 7#b7 and 7#c74 7#e7 ,the ,,irs ,free ,file ,program shall work cooperatively with ,state government agencies to enhance and expand the use of the program to provide needed benefits to the taxpayer while reducing the cost of processing returns4 7b7 ,innovations ,the ,secretary of the ,treasury1 or the ,secretary's delegate1 shall work with the private sector through the ,,irs ,free ,file ,program to identify and implement1 consistent with applicable law1 innovative new program features to improve and simplify the taxpayer's experience with completing and filing individual income tax returns through voluntary compliance4 #bjc4 ,low-income exception for payments otherwise required in connection with a submission of an offer-in-compromise 7a7 ,in general ,section #gabb7;c7 is amended by adding at the end the following new paragraph3 7#c7 ,exception for low-income taxpayers ,paragraph 7#a71 and any user fee otherwise required in connection with the submission of an offer-in-compromise1 shall not apply to any offer-in-compromise with respect to a taxpayer who is an individual with adjusted gross income1 as determined for the most recent taxable year for which such information is available1 which does not exceed #bej percent of the applicable poverty level 7as determined by the ,secretary74 4 7b7 ,effective date ,the amendment made by this section shall apply to offers-in-compromise submitted after the date of the enactment of this ,act4 ,,iii ,sensible ,enforcement #cja4 ,internal ,revenue ,service seizure requirements with respect to structuring transactions ,section #ecag7;c77#b7 of title #ca1 ,united ,states ,code1 is amended-- 7#a7 by striking ,any property and inserting the following3 7,a7 ,in general ,any property 2 and 7#b7 by adding at the end the following3 7,b7 ,internal ,revenue ,service seizure requirements with respect to structuring transactions 7i7 ,property derived from an illegal source ,property may only be seized by the ,internal ,revenue ,service pursuant to subparagraph 7,a7 by reason of a claimed violation of section #ecbd if 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 #ecbd4 7ii7 ,notice ,not later than #cj days after property is seized by the ,internal ,revenue ,service pursuant to subparagraph 7,a71 the ,internal ,revenue ,service shall-- 7,i7 make a good faith effort to find all persons with an ownership interest in such property2 and 7,,ii7 provide each such person with a notice of the seizure and of the person's rights under clause 7iv74 7iii7 ,extension of notice under certain circumstances ,the ,internal ,revenue ,service may apply to a court of competent jurisdiction for one #cj-;day extension of the notice requirement under clause 7ii7 if the ,internal ,revenue ,service can establish probable cause of an imminent threat to national security or personal safety necessitating such extension4 7iv7 ,post-seizure hearing ,if a person with a property interest in property seized pursuant to subparagraph 7,a7 by the ,internal ,revenue ,service requests a hearing by a court of competent jurisdiction within #cj days after the date on which notice is provided under subclause 7ii71 such property shall be returned unless the court holds an adversarial hearing and finds within #cj days of such request 7or such longer period as the court may provide1 but only on request of an interested party7 that there is probable cause to believe that there is a violation of section #ecbd 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 #ecbd4 4 #cjb4 ,exclusion of interest received in action to recover property seized by the ,internal ,revenue ,service based on structuring transaction 7a7 ,in general ,part ,,iii of subchapter ,b of chapter #a is amended by inserting before section #adj the following new section3 #aci;,g4 ,interest received in action to recover property seized by the ,internal ,revenue ,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 #ecag7;c77#b7 of title #ca1 ,united ,states ,code1 by reason of a claimed violation of section #ecbd of such title4 4 7b7 ,clerical amendment ,the table of sections for part ,,iii of subchapter ,b of chapter #a is amended by inserting before the item relating to section #adj the following new item3 ,sec4 #aci;,g4 ,interest received in action to recover property seized by the ,internal ,revenue ,service based on structuring transaction4 4 7c7 ,effective date ,the amendments made by this section shall apply to interest received on or after the date of the enactment of this ,act4 #cjc4 ,clarification of equitable relief from joint liability 7a7 ,in general ,section #fjae is amended-- 7#a7 in subsection 7e71 by adding at the end the following new paragraph3 7#g7 ,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-- 7,a7 the administrative record established at the time of the determination1 and 7,b7 any additional newly discovered or previously unavailable evidence4 1 and 7#b7 by amending subsection 7f7 to read as follows3 7f7 ,equitable relief 7#a7 ,in general ,under procedures prescribed by the ,secretary1 if-- 7,a7 taking into account all the facts and circumstances1 it is inequitable to hold the individual liable for any unpaid tax or any deficiency 7or any portion of either71 and 7,b7 relief is not available to such individual under subsection 7b7 or 7c71 the ,secretary may relieve such individual of such liability4 7#b7 ,limitation ,a request for equitable relief under this subsection may be made with respect to any portion of any liability that-- 7,a7 has not been paid1 provided that such request is made before the expiration of the applicable period of limitation under section #fejb1 or 7,b7 has been paid1 provided that such request is made during the period in which the individual could submit a timely claim for refund or credit of such payment4 4 7b7 ,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 ,act4 #cjd4 ,modification of procedures for issuance of third-party summons 7a7 ,in general ,section #gfji7;f7 is amended by adding at the end the following flush sentence3 ,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 pertains to the failure 7or potential failure7 of the person or group or class of persons referred to in paragraph 7#b7 to comply with one or more provisions of the internal revenue law which have been identified for purposes of such paragraph4 4 7b7 ,effective date ,the amendments made by this section shall apply to summonses served after the date of the enactment of this ,act4 #cje4 ,establishment of income threshold for referral to private debt collection 7a7 ,in general ,section #fcjf7;d77#c7 is amended by striking or at the end of subparagraph 7,c71 by adding or at the end of subparagraph 7,d71 and by inserting after subparagraph 7,d7 the following new subparagraph3 7,e7 in the case of a tax receivable which is identified by the ,secretary 7or the ,secretary's delegate7 during the period beginning on the date which is #ahj days after the date of the enactment of this ,act and ending on ,december #ca1 #bjai1 a taxpayer who is an individual with adjusted gross income1 as determined for the most recent taxable year for which such information is available1 which does not exceed #bej percent of the applicable poverty level 7as determined by the ,secretary71 4 7b7 ,effective date ,the amendments made by this section shall apply to tax receivables identified by the ,secretary 7or the ,secretary's delegate7 after the date which is #ahj days after the date of the enactment of this ,act4 #cjf4 ,reform of notice of contact of third parties 7a7 ,in general ,section #gfjb7;c77#a7 is amended to read as follows3 7#a7 ,general notice ,an officer or employee of the ,internal ,revenue ,service may not contact 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 7not greater than #a year7 which is specified in a notice which-- 7,a7 informs the taxpayer that contacts with persons other than the taxpayer are intended to be made during such period1 and 7,b7 except as otherwise provided by the ,secretary1 is provided to the taxpayer not later than #de days before the beginning of such period4 ,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 therein that1 in the aggregate1 exceed #a year4 ,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 notice4 ,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 contact4 4 7b7 ,effective date ,the amendment made by this section shall apply to notices provided1 and contacts of persons made1 after the date which is #de days after the date of the enactment of this ,act4 #cjg4 ,modification of authority to issue designated summons 7a7 ,in general ,clause 7i7 of section #fejc7;j77#b77;,a7 is amended to read as follows3 7i7 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 ,internal ,revenue ,service and the ,chief ,counsel which-- 7,i7 states facts clearly establishing that the ,secretary has made reasonable requests for the information that is the subject of the summons1 and 7,,ii7 is attached to such summons1 4 7b7 ,establishment that reasonable requests for information were made ,subsection 7j7 of section #fejc is amended by adding at the end the following new paragraph3 7#d7 ,establishment that reasonable requests for information were made ,in any court proceeding described in paragraph 7#c71 the ,secretary shall establish that reasonable requests were made for the information that is the subject of the summons4 4 7c7 ,effective date ,the amendments made by this section shall apply to summonses issued after the date of the enactment of this ,act4 #cjh4 ,limitation on access of non-,internal ,revenue ,service employees to returns and return information 7a7 ,in general ,section #gfjb is amended by adding at the end the following new subsection3 7f7 ,limitation on access of persons other than ,internal ,revenue ,service officers and employees ,the ,secretary shall not1 under the authority of section #fajc7n71 provide any books1 papers1 records1 or other data obtained pursuant to this section to any person authorized under section #fajc7n71 except when such person requires such information for the sole purpose of providing expert evaluation and assistance to the ,internal ,revenue ,service4 ,no person other than an officer or employee of the ,internal ,revenue ,service or the ,office of ,chief ,counsel may1 on behalf of the ,secretary1 question a witness under oath whose testimony was obtained pursuant to this section4 4 7b7 ,effective date 7#a7 ,in general ,except as provided in paragraph 7#b71 the amendment made by this section shall take effect on the date of the enactment of this ,act4 7#b7 ,application to contracts in effect ,the amendment made by this section shall apply to any contract in effect under section #fajc7n7 of the ,internal ,revenue ,code of #aihf1 pursuant to temporary ,treasury ,regulation section #cja4gfjb-a,t proposed in ,internal ,revenue ,bulletin #bjad-bh1 ,treasury ,regulation section #cja4gfjb-a7;b77#c71 or any similar or successor regulation1 that is in effect on the date of the enactment of this ,act4 ,,iv ,organizational modernization #dja4 ,modification of title of ,commissioner of ,internal ,revenue and related officials 7a7 ,in general ,section #ghjc7;a77#a77;,a7 is amended by striking ,commissioner of ,internal ,revenue and inserting ,administrator of the ,internal ,revenue ,service4 7b7 ,conforming amendments related to section #ghjc 7#a7 ,subsections 7a77#a77;,b71 7a77#a77;,c71 7b77#c71 7c77#a77;,b77i71 and 7c77#a77;,b77ii7 of section #ghjc are each amended by striking ,commissioner of ,internal ,revenue and inserting ,administrator of the ,internal ,revenue ,service4 7#b7 ,section #ghjc7;b77#b77;,a7 is amended by striking ,commissioner's and inserting ,administrator's4 7#c7 ,subsections 7a77#a77;,d71 7a77#a77;,e71 7a77#b71 7a77#c71 7a77#d71 7b77#b77;,a71 7b77#b77;,d71 7b77#c71 7c77#b77;,b77iii71 7c77#b77;,c77iv71 and 7c77#c7 of section #ghjc1 as amended by the preceding paragraphs of this subsection1 are amended by striking ,commissioner each place it appears therein and inserting ,administrator4 7#d7 ,the heading of section #ghjc is amended by striking ,commissioner of ,internal ,revenue and inserting ,administrator of the ,internal ,revenue ,service4 7#e7 ,the heading of section #ghjc7;a7 is amended by striking ,commissioner of ,internal ,revenue and inserting ,administrator of the ,internal ,revenue ,service4 7#f7 ,the heading of section #ghjc7;c77#c7 is amended by striking ,commissioner and inserting ,administrator4 7#g7 ,the table of sections for subchapter ,a of chapter #hj is amended by striking the item relating to section #ghjc and inserting the following new item3 ,sec4 #ghjc4 ,administrator of the ,internal ,revenue ,service2 other officials4 4 7c7 ,other conforming amendments to the ,internal ,revenue ,code of #aihf 7#a7 ,section #fcjg7;c7 is amended by striking ,commissioner of ,internal ,revenue and inserting ,administrator of the ,internal ,revenue ,service4 7#b7 ,section #ffgc7;a77#b77;,b7 is amended by striking ,commissioner of ,internal ,revenue and inserting ,administrator of the ,internal ,revenue ,service4 7#c7 ,section #fgjg7;c7 is amended by striking ,commissioner and inserting ,administrator4 7#d7 ,section #fgjg;,a7d7 is amended-- 7,a7 in paragraph 7#a71 by striking ,commissioner of ,internal ,revenue and inserting ,administrator of the ,internal ,revenue ,service1 and 7,b7 in paragraph 7#c71 by striking ,commissioner each place it appears and inserting ,administrator4 7#e7 7,a7 ,subsections 7a7 and 7g7 of section #gcde are each amended by striking ,commissioner of ,internal ,revenue and inserting ,administrator of the ,internal ,revenue ,service4 7,b7 ,section #gcde7;g7 is amended-- 7i7 by striking ,deputy ,commissioner for ,services and ,enforcement and inserting ,deputy ,administrator for ,services and ,enforcement1 and 7ii7 by striking ,commissioner of an operating division and inserting ,administrator of an operating division4 7,c7 ,subsections 7c77#a71 7d7 and 7e77#a7 of section #gcde are each amended by striking ,commissioner each place it appears therein and inserting ,administrator4 7#f7 ,section #gdce7;e7 is amended by striking ,commissioner each place it appears therein and inserting ,administrator4 7#g7 ,section #gdji7;a77#b77;,b7 is amended by striking ,commissioner of ,internal ,revenue and inserting ,administrator of the ,internal ,revenue ,service4 7#h7 ,section #gfjh7;c7 is amended-- 7,a7 in paragraph 7#a71 by striking the ,commissioner of ,internal ,revenue 7or1 if designated by the ,commissioner1 the ,deputy ,commissioner or an ,assistant ,commissioner of ,internal ,revenue7 and inserting the ,administrator of the ,internal ,revenue ,service 7or1 if designated by the ,administrator1 the ,deputy ,administrator or an ,assistant ,administrator of the ,internal ,revenue ,service71 and 7,b7 in paragraph 7#b7 by striking ,commissioner and inserting ,administrator4 7#i7 ,section #gfaa7;b77#c77;,c7 is amended by striking regional commissioner and inserting regional administrator4 7#aj7 ,section #ggja7;a77#ac7 is amended to read as follows3 7#ac7 ,administrator ,the term ,administrator1 except where the context clearly indicates otherwise1 means the ,administrator of the ,internal ,revenue ,service4 4 7#aa7 7,a7 ,section #ghjd7;a7 is amended by striking ,commissioner of ,internal ,revenue and inserting ,administrator of the ,internal ,revenue ,service4 7,b7 ,subsections 7a71 7b77#a71 and 7b77#b7 of section #ghjd7;a71 as amended by subparagraph 7,a71 are each amended by striking ,commissioner each place it appears therein and inserting ,administrator4 7#ab7 ,section #ghaa7;c77#a7 is amended by striking the ,commissioner of ,internal ,revenue1 or the ,deputy ,commissioner of ,internal ,revenue and inserting the ,administrator of the ,internal ,revenue ,service1 or the ,deputy ,commissioner of the ,internal ,revenue ,service4 7d7 ,amendments to section #h;,d of the ,inspector ,general ,act of #aigh 7#a7 ,subsections 7g77#b71 7k77#a77;,c71 7l77#a71 and 7l77#b77;,a7 of section #h;,d of the ,inspector ,general ,act of #aigh are each amended by striking ,commissioner of ,internal ,revenue and inserting ,administrator of the ,internal ,revenue ,service4 7#b7 ,section #h;,d7l77#b77;,b7 of such ,act is amended by striking ,commissioner each place it appears therein and inserting ,administrator4 7e7 ,other references ,any reference in any provision of law1 or regulation or other guidance1 to the ,commissioner of ,internal ,revenue1 or to any ,deputy or ,assistant ,commissioner of ,internal ,revenue1 or to a ,commissioner of any division or region of the ,internal ,revenue ,service1 shall be treated as a reference to the ,administrator of the ,internal ,revenue ,service1 or to the appropriate ,deputy or ,assistant ,administrator of the ,internal ,revenue ,service1 or to the appropriate ,administrator of such division or region1 respectively4 7f7 ,continuity ,in the case of any individual appointed by the ,president1 by and with the advice and consent of the ,senate1 as ,commissioner of ,internal ,revenue under section #ghjc7;a77#a77;,a7 of the ,internal ,revenue ,code of #aihf1 and serving in such position immediately before the date of the enactment of this ,act1 the amendments made by this section shall be construed as changing the title of such individual and shall not be construed to-- 7#a7 require the reappoint of such individual under such section1 or 7#b7 alter the remaining term of such person under section #ghjc7;a77#a77;,b74 #djb4 ,office of the ,national ,taxpayer ,advocate 7a7 ,taxpayer ,advocate ,directives 7#a7 ,in general ,section #ghjc7;c7 is amended by adding at the end the following new paragraph3 7#e7 ,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-- 7,a7 the ,administrator or a ,deputy ,administrator shall modify1 rescind1 or ensure compliance with such directive not later than #ij days after the issuance of such directive1 and 7,b7 in the case of any directive which is modified or rescinded by a ,deputy ,administrator1 the ,national ,taxpayer ,advocate may 7not later than #ij days after such modification or rescission7 appeal to the ,administrator and the ,administrator shall 7not later than #ij days after such appeal is made7 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 appeal4 4 7#b7 ,report to certain committees of ,congress regarding directives ,section #ghjc7;c77#b77;,b77ii7 is amended by redesignating subclauses 7,,viii7 through 7,,xi7 as subclauses 7,,ix7 through 7,,xii71 respectively1 and by inserting after subclause 7,,vii7 the following new subclause3 7,,viii7 identify any ,taxpayer ,advocate ,directive which was not honored by the ,internal ,revenue ,service in a timely manner1 as specified under paragraph 7#e72 4 7b7 ,national ,taxpayer ,advocate annual reports to ,congress 7#a7 ,inclusion of most serious taxpayer problems ,section #ghjc7;c77#b77;,b77ii77,,iii7 is amended by striking at least #bj and inserting the #aj4 7#b7 ,coordination with ,treasury ,inspector ,general for ,tax ,administration ,section #ghjc7;c77#b7 is amended by adding at the end the following new subparagraph3 4 7,e7 ,coordination with ,treasury ,inspector ,general for ,tax ,administration ,before beginning any research or study1 the ,national ,taxpayer ,advocate shall coordinate with the ,treasury ,inspector ,general for ,tax ,administration to ensure that the ,national ,taxpayer ,advocate does not duplicate any action that the ,treasury ,inspector ,general for ,tax ,administration has already undertaken or has a plan to undertake4 4 7#c7 ,statistical support 7,a7 ,in general ,section #fajh is amended by adding at the end the following new subsection3 7d7 ,statistical support for ,national ,taxpayer ,advocate ,the ,secretary shall1 upon request of the ,national ,taxpayer ,advocate1 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 #ghjc7;c77#b77;,b77ii74 ,such statistical support shall include statistical studies1 compilations1 and the review of information provided by the ,national ,taxpayer ,advocate for statistical validity and sound statistical methodology4 4 7,b7 ,disclosure of review ,section #ghjc7;c77#b77;,b77ii71 as amended by subsection 7a71 is amended by redesignating subclause 7,,xii7 as subclause 7,,xiii7 and by inserting after subclause 7,,xi7 the following new subclause3 7,,xii7 with respect to any statistical information included in such report1 include a statement of whether such statistical information was reviewed or provided by the ,secretary under section #fajh7;d7 and1 if so1 whether the ,secretary determined such information to be statistically valid and based on sound statistical methodology4 4 7,c7 ,conforming amendment ,section #ghjc7;c77#b77;,b77iii7 is amended by adding at the end the following3 ,the preceding sentence shall not apply with respect to statistical information provided to the ,secretary for review1 or received from the ,secretary1 under section #fajh7;d744 7c7 ,salary of ,national ,taxpayer ,advocate ,section #ghjc7;c77#a77;,b77i7 is amended by striking 1 or1 if the ,secretary of the ,treasury so determines1 at a rate fixed under section #iejc of such title4 7d7 ,effective date 7#a7 ,in general ,except as otherwise provided in this subsection1 the amendments made by this section shall take effect on the date of the enactment of this ,act4 7#b7 ,salary of ,national ,taxpayer ,advocate ,the amendment made by subsection 7c7 shall apply to compensation paid to individuals appointed as the ,national ,taxpayer ,advocate after the date of the enactment of this ,act4 #djc4 ,elimination of ,,irs ,oversight ,board 7a7 ,in general ,subchapter ,a of chapter #hj is amended by striking section #ghjb 7and by striking the item relating to such section in the table of sections of such subchapter74 7b7 ,conforming amendments 7#a7 ,section #didf7;c7 is amended by adding or at the end of paragraph 7#e71 by striking 1 or at the end of paragraph 7#f7 and inserting a period1 and by striking paragraph 7#g74 7#b7 ,section #fajc7;h7 is amended by striking paragraph 7#f74 7#c7 ,section #ghjc7;a7 is amended by striking paragraph 7#d74 7#d7 ,section #ghjc7;c77#a77;,b77ii7 is amended by striking and the ,oversight ,board4 7#e7 ,section #ghjc7;c77#b77;,b77iii7 is amended by striking the ,oversight ,board14 7#f7 ,section #h;,d of the ,inspector ,general ,act of #aigh is amended-- 7,a7 in subsections 7g77#b7 and 7h71 by striking the ,internal ,revenue ,service ,oversight ,board and1 7,b7 in subsection 7l77#a71 by striking or the ,internal ,revenue ,service ,oversight ,board1 and 7,c7 in subsection 7l77#b71 by striking and the ,internal ,revenue ,service ,oversight ,board4 #djd4 ,modernization of ,internal ,revenue ,service organizational structure 7a7 ,in general ,not later than ,september #cj1 #bjbj1 the ,administrator of the ,internal ,revenue ,service shall submit to ,congress a comprehensive written plan to redesign the organization of the ,internal ,revenue ,service4 ,such plan shall-- 7#a7 ensure the successful implementation of the priorities specified by ,congress in this ,act1 7#b7 prioritize taxpayer services to ensure that all taxpayers easily and readily receive the assistance that they need1 7#c7 streamline the structure of the agency including minimizing the duplication of services and responsibilities within the agency1 7#d7 best position the ,internal ,revenue ,service to combat cybersecurity and other threats to the ,internal ,revenue ,service1 and 7#e7 address whether the ,criminal ,investigation ,division of the ,internal ,revenue ,service should report directly to the ,administrator4 7b7 ,repeal of restriction on organizational structure of ,internal ,revenue ,service ,paragraph 7#c7 of section #ajja7;a7 of the ,internal ,revenue ,service ,restructuring and ,reform ,act of #aiih shall cease to apply beginning #a year after the date on which the ,administrator of the ,internal ,revenue ,service submits to ,congress the plan described in subsection 7a74 ,v ,tax ,court #eja4 ,disqualification of judge or magistrate judge of the ,tax ,court 7a7 ,in general ,part ,,ii of subchapter ,c of chapter #gf is amended by adding at the end the following new section3 #gdfg4 ,disqualification of judge or magistrate judge of the ,tax ,court ,section #dee of title #bh1 ,united ,states ,code1 shall apply to judges and magistrate judges of the ,tax ,court and to proceedings of the ,tax ,court4 4 7b7 ,clerical amendment ,the table of sections for such part is amended by adding at the end the following new item3 ,sec4 #gdfg4 ,disqualification of judge or magistrate judge of the ,tax ,court4 4 #ejb4 ,opinions and judgments 7a7 ,in general ,section #gdei is amended by striking all the precedes subsection 7c7 and inserting the following3 #gdei4 ,opinions and judgments 7a7 ,requirement ,an opinion upon any proceeding instituted before the ,tax ,court and a judgment thereon shall be made as quickly as practicable4 ,the judgment shall be made by a judge in accordance with the opinion of the ,tax ,court1 and such judgment so made shall1 when entered1 be the judgment of the ,tax ,court4 7b7 ,inclusion of findings of fact in opinion ,it shall be the duty of the ,tax ,court and of each division to include in its opinion or memorandum opinion upon any proceeding1 its findings of fact4 ,the ,tax ,court shall issue in writing all of its findings of fact1 opinions1 and memorandum opinions4 ,subject to such conditions as the ,tax ,court may by rule provide1 the requirements of this subsection and of section #gdfj are met if findings of fact or opinion are stated orally and recorded in the transcript of the proceedings4 4 7b7 ,conforming amendments to section #gdei 7#a7 ,subsections 7c71 7d71 7e71 and 7f7 of section #gdei are each amended by striking decision each place it appears and inserting judgment4 7#b7 ,the headings of subsections 7c71 7d71 and 7e7 of section #gdei are each amended by striking decision and inserting judgment4 7#c7 ,the item relating to section #gdei in the table of sections for part ,,ii of subchapter ,c of chapter #gf is amended to read as follows3 ,sec4 #gdei4 ,opinions and judgments4 4 7c7 ,other conforming amendments 7#a7 ,the following provisions are each amended by striking decision and inserting judgment3 7,a7 ,section #acac7;a77#a74 7,b7 ,section #fbac7;a74 7,c7 ,section #fbad7;d74 7,d7 ,section #fbbe7;a77#b74 7,e7 ,section #fbbf7;g74 7,f7 ,section #fbbh7;a77#f74 7,g7 ,subsections 7a77#c77;,b7 and 7c77#a77;,a77ii7 of section #fbcj4 7,h7 ,section #fbdg7;d74 7,i7 ,section #fbeb7;e74 7,j7 ,section #fdjd7;h77#b77;,c74 7,k7 ,section #fejc7;a77#a74 7,l7 ,section #ffgc7;a77#a77;,c74 7,m7 ,subsections 7c71 7f71 and 7g7 of section #fhfa4 7,n7 ,section #fhfc7;b77#c77;,c74 7,o7 ,section #gdbh7;a74 7,p7 ,section #gdbh7;c77#a77;,c77i74 7,q7 ,section #gdcj7;f77#c74 7,r7 ,section #gdcf7;c77#b74 7,s7 ,section #gdfa7;b77#b74 7,t7 ,subsections 7a77#d71 7b71 and 7d7 of section #gdfc4 7,u7 ,subsections 7a77#b77;,b7 and 7b77#d7 of section #gdgf4 7,v7 ,section #gdgg7;a74 7,w7 ,section #gdgh7;a77#b74 7,x7 ,subsections 7a77#b7 and 7c7 of section #gdgi4 7#b7 ,the following provisions are each amended by striking decision each place it appears and inserting judgment3 7,a7 ,subsections 7a7 and 7b77#c7 of section #fbae4 7,b7 ,section #fbbf7;h74 7,c7 ,section #fbdg7;e74 7,d7 ,subsections 7d7 and 7e7 of section #fhfa4 7,e7 ,section #fhfc7;b77#b74 7,f7 ,section #gdbb4 7,g7 ,subsections 7a7 and 7b7 of section #gdfj4 7,h7 ,subsections 7a71 7b71 7c71 and 7d7 of section #gdfc4 7,i7 ,section #gdhb4 7,j7 ,section #gdhc4 7,k7 ,section #gdhe7;b74 7,l7 ,section #gdha4 7#c7 ,sections #gdbb and #gdhb are each amended by striking decisions each place it appears and inserting judgments4 7#d7 ,section #gdcj7;f77#a7 is amended by striking decision or both places it appears4 7#e7 ,subsections 7a7 and 7b7 of section #gdfj are each amended by striking report each place it appears and inserting opinion4 7#f7 ,section #gdfa7;a7 is amended-- 7,a7 by striking reports and inserting opinions1 and 7,b7 by striking report and inserting opinion4 7#g7 ,section #gdfb is amended by striking reports each place it appears and inserting opinions4 7#h7 ,section #gdhg7a7 is amended by striking decisions and inserting judgments4 7#i7 ,the headings of sections #fbad7;b71 #gdfc7;b71 #gdha7;a71 #gdha7;b71 #gdha7;d71 and #gdhe7;b7 are each amended by striking decisions and inserting judgments4 7#aj7 ,the headings of sections #fbbf7;h71 #fbdg7;e71 #fhfa7;c71 #fhfa7;d71 #gddc;,a7c71 #gdha7;a77#b71 and #gdha7;a77#c7 are each amended by striking decision and inserting judgment4 7#aa7 ,the headings of sections #fhfc7;b77#b71 #fhfc7;b77#c71 #gdcj7;f77#c71 and #gdhb7;a77#b77;,b7 are each amended by striking decision and inserting judgment4 7#ab7 ,the heading of section #gdcf7;c77#b7 is amended by striking decisions and inserting judgment4 7#ac7 ,the heading of section #gdfj7;a7 is amended by striking reports and inserting opinions4 7#ad7 ,the heading of section #gdfb is amended by striking reports and inserting opinions4 7#ae7 ,the heading of subchapter ,d of chapter #gf is amended by striking decisions and inserting judgments4 7#af7 ,the heading of section #gdha is amended by striking decision and inserting judgment4 7#ag7 ,the item relating to section #gdfb in the table of sections for part ,,ii of subchapter ,c of chapter #gf is amended to read as follows3 ,sec4 #gdfb4 ,publication of opinions4 4 7#ah7 ,the item relating to subchapter ,d in the table of subchapters for chapter #gf is amended to read as follows3 ,subchapter ,d4--,court ,review of ,tax ,court ,judgments 4 7#ai7 ,the item relating to section #gdha in the table of sections for part ,,iii of subchapter ,d of chapter #gf is amended to read as follows3 ,sec4 #gdha4 ,date when ,tax ,court judgment becomes final4 4 7d7 ,continuing effect of legal documents ,all orders1 decisions1 reports1 rules1 permits1 agreements1 grants1 contracts1 certificates1 licenses1 registrations1 privileges1 and other administrative actions1 in connection with the ,tax ,court1 which are in effect at the time this section takes effect1 or were final before the effective date of this section and are to become effective on or after the effective date of this section1 shall continue in effect according to their terms until modified1 terminated1 superseded1 set aside1 or revoked in accordance with law by the ,tax ,court4 #ejc4 ,title of special trial judge changed to magistrate judge of the ,tax ,court 7a7 ,in general ,section #gddc;,a is amended-- 7#a7 by striking special trial judges in subsections 7a7 and 7e7 and inserting magistrate judges of the ,tax ,court1 7#b7 by striking special trial judges of the court in subsection 7b7 and inserting magistrate judges of the ,tax ,court1 and 7#c7 by striking special trial judge in subsections 7c7 and 7d7 and inserting magistrate judge of the ,tax ,court4 7b7 ,conforming amendments 7#a7 ,the heading of section #gddc;,a is amended by striking 8,special trial judges0 and inserting ,magistrate judges of the ,tax ,court4 7#b7 ,the heading of section #gddc;,a7b7 is amended by striking ,special trial judges and inserting ,magistrate judges of the ,tax ,court4 7#c7 ,the item relating to section #gddc;,a in the table of sections for part ,i of subchapter ,c of chapter #gf is amended to read as follows3 ,sec4 #gddc;,a4 ,magistrate judges of the ,tax ,court4 4 7#d7 ,the heading of section #gddh is amended by striking ,special trial judges and inserting ,magistrate judges of the ,tax ,court4 7#e7 ,section #gddh is amended-- 7,a7 by striking special trial judge's each place it appears in subsections 7a77#f71 7c77#a71 7d71 and 7m77#a7 and inserting magistrate judge of the ,tax ,court's1 and 7,b7 by striking special trial judge each place it appears other than in subsection 7n7 and inserting magistrate judge of the ,tax ,court4 7#f7 ,section #gddh7n7 is amended-- 7,a7 by striking special trial judge which are allowable and inserting magistrate judge of the ,tax ,court which are allowable1 and 7,b7 by striking special trial judge of the ,tax ,court both places it appears and inserting magistrate judge of the ,tax ,court4 7#g7 ,the heading of section #gddh7;b77#b7 is amended by striking ,special trial judges and inserting ,magistrate judges of the ,tax ,court4 7#h7 ,the item relating to section #gddh in the table of sections for part ,i of subchapter ,c of chapter #gf is amended to read as follows3 ,sec4 #gddh4 ,annuities to surviving spouses and dependent children of judges and magistrate judges of the ,tax ,court4 4 7#i7 ,section #gdef7;a7 is amended-- 7,a7 by striking special trial judge each place it appears and inserting magistrate judge1 and 7,b7 by striking 7or by the clerk and inserting of the ,tax ,court 7or by the clerk4 7#aj7 ,section #gdff7;a7 is amended by striking special trial judge and inserting magistrate judge4 7#aa7 ,section #gdgj;,a is amended by striking special trial judges both places it appears in subsections 7a7 and 7b7 and inserting magistrate judges4 7#ab7 ,section #gdga7;a77#b77;,a7 is amended by striking special trial judges and inserting magistrate judges4 7#ac7 ,section #gdga7;c7 is amended-- 7,a7 by striking ,special trial judges in the heading and inserting ,magistrate judges of the ,tax ,court1 and 7,b7 by striking special trial judges and inserting magistrate judges4 #ejd4 ,repeal of deadwood related to ,board of ,tax ,appeals 7a7 ,section #gdei is amended by striking subsection 7f7 and redesignating subsection 7g7 as subsection 7f74 7b7 ,section #gddg7;a77#c7 is amended to read as follows3 7#c7 ,in any determination of length of service as judge or as a judge of the ,tax ,court of the ,united ,states there shall be included all periods 7whether or not consecutive7 during which an individual served as judge4 4 ,april #ac1 #bjah ,reported from the ,committee on ,ways and ,means with an amendment,april #ac1 #bjah,the ,committee on ,financial ,services discharged2 committed to the ,committee of the ,whole ,house on the ,state of the ,union and ordered to be printed