,,ii #aaeth ,,congress #b;d ,session ,s4 #cbgh ,,in ,,the ,,senate ,,of ,,the ,,united ,,states ,july #bf1 #bjah ,mr4 ,portman 7for himself and ,mr4 ,cardin7 introduced the following bill2 which was read twice and referred to the ,committee on ,finance ,a ,,bill ,to amend the ,internal ,revenue ,code of #aihf to provide additional protections to taxpayers4 #a4 ,short title2 table of contents 7a7 ,short title ,this ,act may be cited as the ,protecting ,taxpayers ,act4 7b7 ,table of contents ,the table of contents of this ,act is as follows3 ,sec4 #a4 ,short title2 table of contents4 ,sec4 #b4 ,amendment of ,internal ,revenue ,code of #aihf4 ,,title ,i--,management and ,training ,sec4 #aja4 ,internal ,revenue ,service ,management ,board4 ,sec4 #ajb4 ,comprehensive training strategy4 ,sec4 #ajc4 ,streamlining centralized training program approval4 ,,title ,,ii--,taxpayer ,protection ,sec4 #bja4 ,quarterly notices of delinquency4 ,sec4 #bjb4 ,regulation of tax return preparers4 ,sec4 #bjc4 ,misdirected tax refund deposits4 ,,title ,,iii--,small ,business ,tax ,administration and ,compliance ,sec4 #cja4 ,safe harbor for employer tip reporting4 ,sec4 #cjb4 ,information reporting of income from certain rentals of space in the beauty service industry4 ,sec4 #cjc4 ,release of ,federal tax levies which cause business hardship4 ,sec4 #cjd4 ,extension of time for making ,s corporation elections4 ,sec4 #cje4 ,quarterly reporting of estimated tax payments4 ,,title ,,iv--,retirement plans and savings ,sec4 #dja4 ,expansion of employee plans compliance resolution system4 ,,title ,v--,assistance for low-income taxpayers ,sec4 #eja4 ,establishment of income threshold for referral to private debt collection4 ,sec4 #ejb4 ,return preparation programs for applicable taxpayers4 ,sec4 #ejc4 ,low-income taxpayer clinics4 ,sec4 #ejd4 ,low-income exception for payments otherwise required in connection with a submission of an offer-in-compromise4 ,,title ,,vi--,appeals ,process ,sec4 #fja4 ,right to independent conference4 ,sec4 #fjb4 ,access to case files4 ,sec4 #fjc4 ,ensuring taxpayer right to appeal4 ,sec4 #fjd4 ,limitation on designation of cases as not eligible for referral to ,independent ,office of ,appeals4 ,sec4 #fje4 ,procedures related to ,secretarial authority to designate cases for litigation4 ,,title ,,vii--,miscellaneous ,sec4 #gja4 ,modification of authority to issue designated summons4 ,sec4 #gjb4 ,streamlined critical pay authority for information technology positions4 ,sec4 #gjc4 ,uniform standards for the use of electronic signatures for disclosure authorizations to1 and other authorizations of1 practitioners4 ,sec4 #gjd4 ,limitation on access of non-,internal ,revenue ,service employees to returns and return information4 #b4 ,amendment of ,internal ,revenue ,code of #aihf ,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 ,i ,management and ,training #aja4 ,internal ,revenue ,service ,management ,board 7a7 ,in general ,section #ghjb is amended-- 7#a7 in the heading1 by striking ,oversight ,board and inserting ,management ,board1 7#b7 by striking ,oversight ,board each place it appears and inserting ,management ,board1 7#c7 in subsection 7b7-- 7,a7 in paragraph 7#a7-- 7i7 in subparagraph 7,a71 by striking six and inserting four1 7ii7 by striking subparagraph 7,b7 and inserting the following3 7,b7 one non-voting member shall be the ,deputy ,secretary of the ,treasury4 1 7iii7 in subparagraph 7,c71 by inserting non-voting before member1 and 7iv7 by adding at the end the following new subparagraph3 7,e7 one non-voting member shall be the ,deputy ,inspector ,general for ,tax ,administration4 1 7,b7 in paragraph 7#d71 by striking ,five members and inserting ,three voting members1 and 7,c7 in paragraph 7#e71 by striking subparagraph 7,b7 and inserting the following3 7,b7 ,ex officio members ,an individual described in subparagraph 7,b71 7,c71 or 7,e7 of paragraph 7#a7 shall be removed upon termination of service in the office described in such subparagraph4 1 7#d7 in subsection 7c77#a77;,b71 by inserting and that all employees of the ,internal ,revenue ,service are familiar with and act in accordance with the ,taxpayer ,bill of ,rights before the period1 and 7#e7 in subsection 7d7-- 7,a7 in paragraph 7#a7-- 7i7 in subparagraph 7,a71 by striking and at the end1 7ii7 by striking subparagraph 7,b7 and inserting the following3 7,b7 long-range strategic plans1 and 1 and 7iii7 by adding at the end the following3 7,c7 an annual performance report and plan4 1 7,b7 in paragraph 7#c7-- 7i7 in subparagraph 7,b7-- 7,i7 by striking selection1 evaluation1 and compensation and inserting selection and evaluation1 and 7,,ii7 by striking and at the end1 7ii7 by redesignating subparagraph 7,c7 as subparagraph 7,d71 and 7iii7 by inserting after subparagraph 7,b7 the following3 7,c7 review and approve the ,commissioner's compensation of ,internal ,revenue ,service senior executives described in subparagraph 7,b72 and 1 7,c7 in paragraph 7#d7-- 7i7 in subparagraph 7,b71 by striking and at the end1 7ii7 by redesignating subparagraph 7,c7 as subparagraph 7,d71 and 7iii7 by inserting after subparagraph 7,b7 the following3 7,c7 review any changes made to such budget request by the ,office of ,management and ,budget prior to submission of the ,president's annual budget request to ,congress2 and 1 and 7,d7 by inserting after paragraph 7#e7 the following3 7#f7 ,audits ,to direct the ,treasury ,inspector ,general for ,tax ,administration to perform an audit of any programs or operations of the ,internal ,revenue ,service4 4 7b7 ,conforming amendments 7#a7 ,section #didf7;c77#g7 is amended by striking ,oversight ,board and inserting ,management ,board4 7#b7 ,paragraph 7#f7 of section #fajc7;h7 is amended-- 7,a7 in the heading1 by striking ,oversight ,board and inserting ,management ,board1 and 7,b7 by striking ,oversight ,board each place it appears and inserting ,management ,board4 7#c7 ,section #ghjc is amended-- 7,a7 in subsection 7a77#d71 by striking ,oversight ,board and inserting ,management ,board1 and 7,b7 in subsection 7c7-- 7i7 in paragraph 7#a77;,b77ii71 by striking ,oversight ,board and inserting ,management ,board1 and 7ii7 in paragraph 7#b77;,b77iii71 by striking ,oversight ,board and inserting ,management ,board4 7c7 ,effective date ,the amendments made by this section shall take effect on the date of the enactment of this ,act4 #ajb4 ,comprehensive training strategy ,not later than #a year after the date of the enactment of this ,act1 the ,commissioner of ,internal ,revenue1 in consultation with the ,national ,taxpayer ,advocate1 shall submit to ,congress a written report providing a comprehensive training strategy for employees of the ,internal ,revenue ,service1 including-- 7#a7 a plan to streamline current training processes1 including an assessment of the utility of further consolidating internal training programs1 technology1 and funding1 7#b7 a plan to develop annual training regarding taxpayer rights1 including the role of the ,office of the ,taxpayer ,advocate1 7#c7 a plan to improve technology-based training1 including by developing or adopting state-of-the-art training delivery methods1 7#d7 proposals to focus employee training on early1 fair1 and efficient resolution of taxpayer disputes and to ensure consistency of skill development and employee evaluation throughout the ,internal ,revenue ,service1 7#e7 recommendations for improvement of employee recruitment1 and 7#f7 a thorough assessment of the funding necessary to implement such strategy4 #ajc4 ,streamlining centralized training program approval ,the ,secretary of the ,treasury1 or the ,secretary's delegate1 shall modify the policy promulgated under ,treasury ,directive #ab-gj to permit employee training events 7as defined by the ,secretary or the ,secretary's delegate7 for employees of the ,internal ,revenue ,service1 the cost to the ,internal ,revenue ,service of which exceeds #bdi1iii 7but does not exceed #ejj1jjj71 to be approved by a ,deputy ,commissioner of ,internal ,revenue4 ,,ii ,taxpayer ,protection #bja4 ,quarterly notices of delinquency 7a7 ,in general ,section #gebd is amended-- 7#a7 in the heading1 by striking ,annual and inserting ,quarterly1 and 7#b7 by striking annually and inserting each calendar quarter4 7b7 ,effective date ,the amendments made by this section shall apply to any calendar quarter beginning after ,december #ca1 #bjah4 #bjb4 ,regulation of tax return preparers 7a7 ,in general ,subsection 7a7 of section #ccj of title #ca1 ,united ,states ,code1 is amended-- 7#a7 by striking paragraph 7#a7 and inserting the following3 7#a7 regulate-- 7,a7 the practice of representatives of persons before the ,department of the ,treasury2 and 7,b7 the practice of tax return preparers2 and 1 and 7#b7 in paragraph 7#b7-- 7,a7 by inserting or a tax return preparer to prepare tax returns after practice1 7,b7 by inserting or tax return preparer before demonstrate1 and 7,c7 by inserting or in preparing their tax returns1 claims for refund1 or documents in connection with tax returns or claims for refund after cases in subparagraph 7,d74 7b7 ,authority ,to sanction regulated tax return preparers ,subsection 7c7 of section #ccj of title #ca1 ,united ,states ,code1 is amended-- 7#a7 by striking before the ,department1 7#b7 by inserting or tax return preparer after representative each place it appears1 and 7#c7 in paragraph 7#d71 by striking misleads or threatens and all that follows and inserting misleads or threatens-- 7,a7 any person being represented or any prospective person being represented2 or 7,b7 any person or prospective person whose tax return1 claim for refund1 or document in connection with a tax return or claim for refund1 is being or may be prepared4 4 7c7 ,minimum competency standards for tax return preparers ,section #ccj of title #ca1 ,united ,states ,code1 is amended by adding at the end the following new subsection3 7f7 ,tax return preparers 7#a7 ,in general ,any tax return preparer shall demonstrate minimum competency standards under this subsection by-- 7,a7 obtaining an identifying number for securing proper identification of such preparer as described in section #faji7;a77#d7 of the ,internal ,revenue ,code of #aihf2 7,b7 satisfying any examination and annual continuing education requirements as prescribed by the ,secretary2 and 7,c7 completing a background check administered by the ,secretary4 7#b7 ,exemption ,the ,secretary shall exempt tax return preparers who have been subject to comparable examination1 continuing education requirements1 and background checks administered by the ,secretary or any comparable ,state licensing program4 ,such exemption shall extend directly to individuals who are supervised by such preparers and are not required to secure an identification number under section #faji7;a77#d74 4 7d7 ,tax return preparer defined ,section #ccj of title #ca1 ,united ,states ,code1 as amended by subsection 7c71 is amended by adding at the end the following new subsection3 7g7 ,tax return preparer ,for purposes of this section-- 7#a7 ,in general ,the term tax return preparer has the meaning given such term under section #ggja7;a77#cf7 of the ,internal ,revenue ,code of #aihf4 7#b7 ,tax return ,the term tax return has the meaning given to the term return under section #ffif7;e77#a7 of the ,internal ,revenue ,code of #aihf4 7#c7 ,claim for refund ,the term claim for refund has the meaning given such term under section #ffif7;e77#b7 of such ,code4 4 7e7 ,amendments with respect to identifying number 7#a7 ,in general ,section #faji7;a7 is amended by striking paragraph 7#d7 and inserting the following3 7#d7 ,furnishing identifying number of tax return preparer 7,a7 ,in general ,any return or claim for refund prepared by a tax return preparer shall bear such identifying number for securing proper identification of such preparer1 his employer1 or both1 as may be prescribed4 ,for purposes of this paragraph1 the terms return and claim for refund have the respective meanings given to such terms by section #ffif7;e74 7,b7 ,exception ,subparagraph 7,a7 shall not apply to any tax return preparer who prepares a return or claim for refund under the supervision and direction of a tax return preparer who signs the return or claim for refund and is a certified public accountant1 an attorney or enrolled agent4 4 7#b7 ,clarification of rescission authority ,section #faji is amended by inserting after subsection 7d7 the following new subsection3 7e7 ,authority ,to rescind identifying number of tax return preparer 7#a7 ,in general ,the ,secretary may rescind an identifying number issued under subsection 7a77#d7 if-- 7,a7 after notice and opportunity for a hearing1 the preparer is shown to be incompetent or disreputable 7as such terms are used in subsection 7c7 of section #ccj of title #ca1 ,united ,states ,code71 and 7,b7 rescinding the identifying number would promote compliance with the requirements of this title and effective tax administration4 7#b7 ,records ,if an identifying number is rescinded under paragraph 7#a71 the ,secretary shall place in the file in the ,office of the ,director of ,professional ,responsibility the opinion of the ,secretary with respect to the determination1 including-- 7,a7 a statement of the facts and circumstances relating to the determination1 and 7,b7 the reasons for the rescission4 4 7f7 ,,gao study and report on the exchange of information between the ,,irs and ,state taxation authorities 7#a7 ,in general ,not later than #ah months after the date of the enactment of this ,act1 the ,comptroller ,general shall conduct a study and submit to ,congress a report on the sharing of information between the ,secretary of the ,treasury and ,state authorities1 as authorized under section #fajc7;d7 of the ,internal ,revenue ,code of #aihf1 regarding identification numbers issued to paid tax return preparers and return preparer minimum standards4 7#b7 ,increased information sharing ,the study and report described in paragraph 7#a7 shall include an analysis of the impact that increased information sharing between ,federal and ,state authorities would have on efforts to enforce minimum standards on paid tax return preparers4 #bjc4 ,misdirected tax refund deposits ,section #fdjb is amended by adding at the end the following new subsection3 7n7 ,misdirected direct deposit refund ,not later than ,january #a1 #bjai1 the ,secretary shall prescribe regulations to establish procedures to allow for-- 7#a7 taxpayers to report instances in which a refund made by the ,secretary by electronic funds transfer was erroneously delivered to an account at a financial institution for which the taxpayer is not the owner2 7#b7 coordination with financial institutions for the purpose of-- 7,a7 identifying erroneous payments described in paragraph 7#a72 and 7,b7 recovery of the erroneously transferred amounts2 and 7#c7 the refund to be delivered to the correct account of the taxpayer4 4 ,,iii ,small ,business ,tax ,administration and ,compliance #cja4 ,safe harbor for employer tip reporting 7a7 ,in general ,subsection 7q7 of section #caba is amended-- 7#a7 by striking ,for purposes of this chapter and inserting the following3 7#a7 ,in general ,for purposes of this chapter 1 and 7#b7 by adding at the end the following3 7#b7 ,tip program safe harbor ,in the case of an employer for which #a or more employees receive tips in the course of their employment which are considered remuneration for such employment under paragraph 7#a71 the ,secretary shall not initiate a tip examination 7as that term is used in the model ,tip ,reporting ,alternative ,commitment agreement promulgated by the ,internal ,revenue ,service7 of the employer 7except in relation to a tip examination of #a or more employees or former employees of such employer7 if such employer has demonstrated that it has-- 7,a7 established an educational program regarding the applicable laws relating to the proper reporting of tips received by employees for-- 7i7 new employees1 which shall include both verbal explanations and written materials2 and 7ii7 existing employees1 which shall be conducted quarterly2 7,b7 established procedures for employees who receive tips to1 in accordance with section #fjec7;a71 provide monthly reporting of their cash and charged services and any related tips of #bj or greater2 7,c7 complied with any requirements applicable to employers for purposes of filing returns and collection and payment of taxes imposed with respect to tips received by employees2 and 7,d7 maintained employee records related to-- 7i7 contact information for such employees2 and 7ii7 gross receipts from any services subject to tipping and charge receipts for such services for a period of not less than #d calendar years after the calendar year to which such records relate4 4 7b7 ,effective date ,the amendments made by this section shall apply to tips received for services performed after ,december #ca1 #bjah4 #cjb4 ,information reporting of income from certain rentals of space in the beauty service industry 7a7 ,in general ,subpart ,b of part ,,iii of subchapter ,a of chapter #fa is amended by inserting after section #fjej,y the following new section3 #fjej,z4 ,returns with respect to income from certain rentals of space for beauty services 7a7 ,in general ,any person who1 in connection with its trade or business or rental activity1 receives rental income from #b or more individuals providing beauty services in excess of #fjj each for a calendar year for the rental of space to provide such beauty services to third-party patrons1 shall make a return with respect to each such individual1 at such time and in such manner as the ,secretary shall prescribe1 which shall include-- 7#a7 the name1 address1 and ,,tin of such individual1 7#b7 the total amount received from such individual during such calendar year1 including the date and amount of each payment1 and 7#c7 such additional information as the ,secretary may require4 7b7 ,statements ,to be furnished to persons with respect to whom information is required ,to be furnished 7#a7 ,in general ,every person required to make a return under subsection 7a7 shall furnish to each individual whose name is required to be set forth in such return a written statement showing-- 7,a7 the name1 address1 and phone number of the information contact of the person required to make such return1 and 7,b7 the aggregate amount of payments to the person required to be shown on such return4 7#b7 ,furnishing of information ,the written statement required under paragraph 7#a7 shall be furnished to the individual on or before ,january #ca of the year following the calendar year for which the return under subsection 7a7 was made4 7c7 ,regulations and guidance ,the ,secretary may prescribe such regulations and other guidance as may be appropriate or necessary to carry out the purposes of this section1 including rules to prevent duplicative reporting of transactions4 7d7 ,beauty service ,for purposes of this section1 the term beauty service means-- 7#a7 barbering and hair care1 7#b7 nail care1 7#c7 esthetics1 and 7#d7 body and spa treatments4 4 7b7 ,conforming amendments 7#a7 ,section #fgbd7;d77#a77;,b7 is amended by striking or at the end of clause 7xxv71 by striking and at the end of clause 7xxvi7 and inserting or1 and by inserting after clause 7xxvi7 the following new clause3 7xvii7 section #fjej,x7a7 7relating to information reporting with respect to rentals of space for beauty services71 and 4 7#b7 ,paragraph 7#b7 of section #fgbd7;d7 is amended-- 7,a7 by striking or at the end of subparagraph 7,,ii71 7,b7 by striking the period at the end of the first subparagraph 7,,jj7 and inserting a comma1 7,c7 by redesignating the second subparagraph 7,,jj7 as subparagraph 7,,kk71 7,d7 in subparagraph 7,,kk71 as redesignated by subparagraph 7,c71 by striking the period at the end and inserting 1 or1 and 7,e7 by inserting after subparagraph 7,,kk7 the following new subparagraph3 7,,ll7 section #fjej,z7b77#a7 7relating to statements to providers of beauty services74 4 7#c7 ,the table of sections for subpart ,b of part ,,iii of subchapter ,a of chapter #fa is amended by adding after the item relating to section #fjej,y the following new item3 ,sec4 #fjej,z4 ,returns with respect to income from certain rentals of space for beauty services4 4 7c7 ,effective date ,the amendments made by this section shall apply to calendar years after #bjah4 #cjc4 ,release of ,federal tax levies which cause business hardship 7a7 ,in general ,subparagraph 7,d7 of section #fcdc7;a77#a7 is amended by inserting or any trade or business of the taxpayer before 1 or4 7b7 ,criteria for determining business hardship ,subsection 7a7 of section #fcdc is amended by adding at the end the following new paragraph3 7#d7 ,criteria for determining business hardship ,for purposes of making a determination under paragraph 7#a77;,d71 with respect to a trade or business of the taxpayer1 the ,secretary shall take into consideration-- 7,a7 the economic viability of such trade or business1 7,b7 the nature and extent of the hardship1 including the extent to which the taxpayer exercised ordinary business care and prudence1 and 7,c7 any hardships which would be caused to other individuals or businesses if such trade or business were liquidated4 4 7c7 ,effective date ,the amendments made by this section shall take effect on the date of the enactment of this ,act4 #cjd4 ,extension of time for making ,s corporation elections 7a7 ,in general ,subsection 7b7 of section #acfb is amended to read as follows3 7b7 ,when made 7#a7 ,in general ,an election under subsection 7a7 may be made by a small business corporation for any taxable year not later than the due date for filing the return of the ,s corporation for such taxable year 7including extensions74 7#b7 ,certain elections treated as made for next taxable year ,if-- 7,a7 an election under subsection 7a7 is made for any taxable year within the period described in paragraph 7#a71 but 7,b7 either-- 7i7 on #a or more days in such taxable year and before the day on which the election was made the corporation did not meet the requirements of subsection 7b7 of section #acfa1 or 7ii7 #a or more of the persons who held stock in the corporation during such taxable year and before the election was made did not consent to the election1 then such election shall be treated as made for the following taxable year4 7#c7 ,authority to treat late elections1 etc41 as timely ,if-- 7,a7 an election under subsection 7a7 is made for any taxable year after the date prescribed by this subsection for making such election for such taxable year or no such election is made for any taxable year1 and 7,b7 the ,secretary determines that there was reasonable cause for the failure to timely make such election1 the ,secretary may treat such an election as timely made for such taxable year4 7#d7 ,election on timely filed returns ,except as otherwise provided by the ,secretary1 an election under subsection 7a7 for any taxable year may be made on a timely filed return of the ,s corporation for such taxable year4 7#e7 ,secretarial authority ,the ,secretary may prescribe such regulations1 rules1 or other guidance as may be necessary or appropriate for purposes of applying this subsection4 4 7b7 ,coordination with certain other provisions 7#a7 ,qualified subchapter ,s subsidiaries ,section #acfa7;b77#c77;,b7 is amended by adding at the end the following flush sentence3 ,rules similar to the rules of section #acfb7;b7 shall apply with respect to any election under clause 7ii74 4 7#b7 ,qualified subchapter ,s trusts ,section #acfa7;d77#b7 is amended by striking subparagraph 7,d74 7c7 ,revocations ,paragraph 7#a7 of section #acfb7;d7 is amended-- 7#a7 by striking subparagraph 7,d7 in subparagraph 7,c7 and inserting subparagraphs 7,d7 and 7,e71 and 7#b7 by adding at the end the following new subparagraph3 7,e7 ,authority to treat late revocations as timely ,if-- 7i7 a revocation under subparagraph 7,a7 is made for any taxable year after the date prescribed by this paragraph for making such revocation for such taxable year or no such revocation is made for any taxable year1 and 7ii7 the ,secretary determines that there was reasonable cause for the failure to timely make such revocation1 the ,secretary may treat such a revocation as timely made for such taxable year4 4 7d7 ,effective date 7#a7 ,in general ,except as otherwise provided in this subsection1 the amendments made by this section shall apply to elections for taxable years beginning after ,december #ca1 #bjah4 7#b7 ,revocations ,the amendments made by subsection 7c7 shall apply to revocations after ,december #ca1 #bjah4 #cje4 ,quarterly reporting of estimated tax payments 7a7 ,in general ,the table contained in paragraph 7#b7 of section #ffed7;c7 is amended-- 7#a7 by striking ,june #ae and inserting ,july #ae1 and 7#b7 by striking ,september #ae and inserting ,october #ae4 7b7 ,effective date ,the amendments made by this section shall apply to installments due in taxable years beginning after ,december #ca1 #bjah4 ,,iv ,retirement plans and savings #dja4 ,expansion of employee plans compliance resolution system 7a7 ,in general ,except as otherwise provided in regulations prescribed by the ,secretary of the ,treasury or the ,secretary's delegate 7referred to in this section as the ,secretary71 any inadvertent failure to comply with the rules applicable under section #dja7;a71 #djc7;a71 #djc7;b71 #djh7p71 or #djh7k7 of the ,internal ,revenue ,code of #aihf may be self-corrected under the ,employee ,plans ,compliance ,resolution ,system 7as described in ,revenue ,procedure #bjaf-ea or any successor guidance71 except to the extent that such failure was identified by ,secretary prior to any actions that demonstrate a commitment to implement a self-correction4 7b7 ,loan error ,the ,secretary of ,labor shall treat any loan error corrected pursuant to subsection 7a7 as meeting the requirements of the ,voluntary ,fiduciary ,correction ,program of the ,department of ,labor4 7c7 ,,epcrs for ,i,r,as ,the ,secretary shall expand the ,employee ,plans ,compliance ,resolution ,system to allow custodians of individual retirement plans to address inadvertent errors for which the owner of an individual retirement plan was not at fault1 including 7but not limited to7-- 7#a7 waivers of the excise tax that would otherwise apply under section #digd of the ,internal ,revenue ,code of #aihf2 7#b7 under the self-correction component of the ,employee ,plans ,compliance ,resolution ,system1 waivers of the #fj-;day deadline for a rollover where the deadline is missed for reasons beyond the reasonable control of the account owner2 and 7#c7 rules permitting a nonspouse beneficiary to return distributions to an inherited individual retirement plan described in section #djh7;d77#c77;,c7 of the ,internal ,revenue ,code of #aihf in a case where1 due to an inadvertent error by a service provider1 the beneficiary had reason to believe that the distribution could be rolled over without inclusion in income of any part of the distributed amount4 7d7 ,required minimum distribution corrections ,the ,secretary shall expand the ,employee ,plans ,compliance ,resolution ,system to allow plans to which such system applies and custodians of individual retirement plans to self-correct1 without an excise tax1 any inadvertent errors pursuant to which a distribution is made no more than #ahj days after it was required to be made4 7e7 ,additional safe harbors ,the ,secretary shall expand the ,employee ,plans ,compliance ,resolution ,system 7as described in ,revenue ,procedure #bjaf-ea or any successor guidance7 to provide additional safe harbor means of correcting inadvertent failures described in subsection 7a71 including safe harbor means of calculating the earnings that must be restored to a plan in cases where plan assets have been depleted by reason of an inadvertent failure4 ,v ,assistance for low-income taxpayers #eja4 ,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 of the ,treasury 7or the ,secretary's delegate7 after the date which is #ahj days after the date of the enactment of this ,act4 #ejb4 ,return preparation programs for applicable taxpayers 7a7 ,in general ,chapter #gg is amended by inserting after section #gebf the following new section3 #gebf;,a4 ,return preparation programs for applicable taxpayers 7a7 ,establishment of ,volunteer ,income ,tax ,assistance ,matching ,grant ,program ,the ,secretary shall establish a ,community ,volunteer ,income ,tax ,assistance ,matching ,grant ,program under which the ,secretary may1 subject to the availability of appropriated funds1 make grants to provide matching funds for the development1 expansion1 or continuation of qualified return preparation programs assisting applicable taxpayers and members of underserved populations4 7b7 ,use of funds 7#a7 ,in general ,qualified return preparation programs may use grants received under this section for-- 7,a7 ordinary and necessary costs associated with program operation in accordance with cost principles under the applicable ,office of ,management and ,budget circular1 including-- 7i7 wages or salaries of persons coordinating the activities of the program1 7ii7 developing training materials1 conducting training1 and performing quality reviews of the returns prepared under the program1 7iii7 equipment purchases1 and 7iv7 vehicle-related expenses associated with remote or rural tax preparation services1 7,b7 outreach and educational activities described in subsection 7c77#b77;,b71 and 7,c7 services related to financial education and capability1 asset development1 and the establishment of savings accounts in connection with tax return preparation4 7#b7 ,requirement of matching funds ,a qualified return preparation program must provide matching funds on a dollar-for-dollar basis for all grants provided under this section4 ,matching funds may include-- 7,a7 the salary 7including fringe benefits7 of individuals performing services for the program1 7,b7 the cost of equipment used in the program1 and 7,c7 other ordinary and necessary costs associated with the program4 ,indirect expenses1 including general overhead of any entity administering the program1 shall not be counted as matching funds4 7c7 ,application 7#a7 ,in general ,each applicant for a grant under this section shall submit an application to the ,secretary at such time1 in such manner1 and containing such information as the ,secretary may reasonably require4 7#b7 ,priority ,in awarding grants under this section1 the ,secretary shall give priority to applications which demonstrate-- 7,a7 assistance to applicable taxpayers1 with emphasis on outreach to1 and services for1 such taxpayers1 7,b7 taxpayer outreach and educational activities relating to eligibility and availability of income supports available through this title1 including the earned income tax credit1 and 7,c7 specific outreach and focus on one or more underserved populations4 7#c7 ,amounts taken into account ,in determining matching grants under this section1 the ,secretary shall only take into account amounts provided by the qualified return preparation program for expenses described in subsection 7b74 7d7 ,program adherence 7#a7 ,in general ,the ,secretary shall establish procedures for1 and shall conduct not less frequently than once every #e calendar years during which a qualified return preparation program is operating under a grant under this section1 periodic site visits-- 7,a7 to ensure the program is carrying out the purposes of this section1 and 7,b7 to determine whether the program meets such program adherence standards as the ,secretary shall by regulation or other guidance prescribe4 7#b7 ,additional requirements for grant recipients not meeting program adherence standards ,in the case of any qualified return preparation program which-- 7,a7 is awarded a grant under this section1 and 7,b7 is subsequently determined-- 7i7 not to meet the program adherence standards described in paragraph 7#a77;,b71 or 7ii7 not to be otherwise carrying out the purposes of this section1 such program shall not be eligible for any additional grants under this section unless such program provides sufficient documentation of corrective measures established to address any such deficiencies determined4 7e7 ,definitions ,for purposes of this section-- 7#a7 ,qualified return preparation program ,the term qualified return preparation program means any program-- 7,a7 which provides assistance to individuals1 not less than #ij percent of whom are applicable taxpayers1 in preparing and filing ,federal income tax returns1 7,b7 which is administered by a qualified entity1 7,c7 in which all volunteers who assist in the preparation of ,federal income tax returns meet the training requirements prescribed by the ,secretary1 and 7,d7 which uses a quality review process which reviews #ajj percent of all returns4 7#b7 ,qualified entity 7,a7 ,in general ,the term qualified entity means any entity which-- 7i7 is an eligible organization1 7ii7 is in compliance with ,federal tax filing and payment requirements1 7iii7 is not debarred or suspended from ,federal contracts1 grants1 or cooperative agreements1 and 7iv7 agrees to provide documentation to substantiate any matching funds provided pursuant to the grant program under this section4 7,b7 ,eligible organization ,the term eligible organization means-- 7i7 an institution of higher education which is described in section #ajb 7other than subsection 7a77#a77;,c7 thereof7 of the ,higher ,education ,act of #aife 7#bj ,u4,s4,c4 #ajjb71 as in effect on the date of the enactment of this section1 and which has not been disqualified from participating in a program under title ,,iv of such ,act1 7ii7 an organization described in section #eja7;c7 and exempt from tax under section #eja7;a71 7iii7 a local government agency1 including-- 7,i7 a county or municipal government agency1 and 7,,ii7 an ,indian tribe1 as defined in section #d7ac7 of the ,native ,american ,housing ,assistance and ,self-,determination ,act of #aiif 7#be ,u4,s4,c4 #dajc7ac771 including any tribally designated housing entity 7as defined in section #d7bb7 of such ,act 7#be ,u4,s4,c4 #dajc7bb7771 tribal subsidiary1 subdivision1 or other wholly owned tribal entity1 7iv7 a local1 ,state1 regional1 or national coalition 7with one lead organization which meets the eligibility requirements of clause 7i71 7ii71 or 7iii7 acting as the applicant organization71 or 7v7 in the case of applicable taxpayers and members of underserved populations with respect to which no organizations described in the preceding clauses are available-- 7,i7 a ,state government agency1 or 7,,ii7 an office providing ,cooperative ,extension services 7as established at the land-grant colleges and universities under the ,smith-,lever ,act of ,may #h1 #aiad74 7#c7 ,applicable taxpayers ,the term applicable taxpayer means a taxpayer whose income for the taxable year does not exceed an amount equal to the completed phaseout amount under section #cb7;b7 for a married couple filing a joint return with #c or more qualifying children1 as determined in a revenue procedure or other published guidance4 7#d7 ,underserved population ,the term underserved population includes populations of persons with disabilities1 persons with limited ,english proficiency1 ,native ,americans1 individuals living in rural areas1 members of the ,armed ,forces and their spouses1 and the elderly4 7f7 ,special rules and limitations 7#a7 ,duration of grants ,upon application of a qualified return preparation program1 the ,secretary is authorized to award a multi-year grant not to exceed #c years4 7#b7 ,aggregate limitation ,unless otherwise provided by specific appropriation1 the ,secretary shall not allocate more than #cj1jjj1jjj per fiscal year 7exclusive of costs of administering the program7 to grants under this section4 7g7 ,promotion of programs 7#a7 ,in general ,the ,secretary shall promote tax preparation through qualified return preparation programs through the use of mass communications and other means4 7#b7 ,provision of information regarding qualified return preparation programs ,the ,secretary may provide taxpayers information regarding qualified return preparation programs receiving grants under this section4 7#c7 ,,vita grantee referral ,qualified return preparation programs receiving a grant under this section are encouraged1 in appropriate cases1 to-- 7,a7 advise taxpayers of the availability of1 and eligibility requirements for receiving1 advice and assistance from qualified low-income taxpayer clinics receiving funding under section #gebf1 and 7,b7 provide information regarding the location of1 and contact information for1 such clinics4 4 7b7 ,clerical amendment ,the table of sections for chapter #gg is amended by inserting after the item relating to section #gebf the following new item3 ,sec4 #gebf;,a4 ,return preparation programs for applicable taxpayers4 4 #ejc4 ,low-income taxpayer clinics 7a7 ,promotion of clinics ,section #gebf is amended by adding at the end the following new subsection3 7d7 ,promotion of clinics ,the ,secretary is authorized to promote the benefits of and encourage the use of qualified low-income taxpayer clinics through the use of mass communications1 referrals1 and other means4 4 7b7 ,,irs referrals to clinics ,subsection 7c7 of section #gebf is amended by adding at the end the following new paragraph3 7#f7 ,,irs referrals ,notwithstanding any other provision of law1 the ,secretary may refer taxpayers to specific qualified low-income taxpayer clinics receiving funding under this section4 4 7c7 ,effective date ,the amendments made by this section shall take effect on the date of the enactment of this ,act4 #ejd4 ,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 ,,vi ,appeals ,process #fja4 ,right to independent conference 7a7 ,in general ,section #ajja of the ,internal ,revenue ,service ,restructuring and ,reform ,act of #aiih is amended by redesignating subsection 7c7 as subsection 7d7 and by inserting after subsection 7b7 the following new subsection3 7c7 ,right to independent conference ,under the organization plan of the ,internal ,revenue ,service1 a taxpayer shall have the right to a conference with the ,internal ,revenue ,service ,office of ,appeals which does not include personnel from the ,office of ,chief ,counsel for the ,internal ,revenue ,service or the compliance functions of the ,internal ,revenue ,service unless the taxpayer specifically consents to the participation of such personnel4 4 7b7 ,effective date ,this section shall apply to conferences occurring after the date of the enactment of this ,act4 #fjb4 ,access to case files 7a7 ,in general ,in the case of any specified taxpayer with respect to which a conference with the ,internal ,revenue ,service ,office of ,appeals has been scheduled1 the taxpayer shall be 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 7b7 ,taxpayer election ,to expedite conference ,if the taxpayer so elects1 subsection 7a7 shall be applied by substituting the date of such conference for #aj days before the date of such conference4 7c7 ,specified taxpayer ,for purposes of this section3 7#a7 ,in general ,the term specified taxpayer means-- 7,a7 in the case of any taxpayer who is a natural person1 a taxpayer whose adjusted gross income does not exceed #djj1jjj1 and 7,b7 in the case of any other taxpayer1 a taxpayer whose gross receipts do not exceed #e1jjj1jjj4 7#b7 ,aggregation rule ,rules similar to the rules of section #ddh7;c77#b7 of the ,internal ,revenue ,code of #aihf shall apply for purposes of paragraph 7#a77;,b74 7d7 ,effective date ,this section shall apply to conferences occurring after the date which is #a year after the date of the enactment of this ,act4 #fjc4 ,ensuring taxpayer right to appeal 7a7 ,in general ,subsection 7a7 of section #fbab is amended-- 7#a7 by striking ,in general4--,if the ,secretary and inserting ,in general4-- 7#a7 ,authorization ,if-- 7,a7 the ,secretary 1 7#b7 by striking #dd1 he is authorized and inserting #dd1 and 7,b7 the requirements of paragraph 7#b7 have been met with respect to such deficiency1 the ,secretary is authorized 1 and 7#c7 by adding at the end the following new paragraph3 7#b7 ,opportunity for administrative review in the ,office of ,appeals 7,a7 ,in general ,the requirements of this paragraph are met with respect to a deficiency if1 prior to the issuance of the notice of deficiency under paragraph 7#a7-- 7i7 the taxpayer has been issued a letter of proposed deficiency that explains the basis for the determination of deficiency and allows the taxpayer an opportunity for administrative review in the ,internal ,revenue ,service ,office of ,appeals1 and 7ii7 either-- 7,i7 the time provided in such letter for contacting the ,office of ,appeals has expired and the taxpayer has not so contacted such ,office1 or 7,,ii7 the ,office of ,appeals has issued a decision with respect to such deficiency4 7,b7 ,frivolous tax positions ,the ,secretary is authorized to issue regulations limiting the application of subparagraph 7,a7 in cases involving solely the failure or refusal to comply with the tax laws because of moral1 religious1 political1 constitutional1 conscientious1 or similar grounds1 or for other positions listed as frivolous under section #fgjb7;c74 7,c7 ,cases designated for litigation ,subparagraph 7,a7 shall not apply in the case of issues designated for litigation in accordance with section #gabd4 4 7b7 ,opportunity for appeal if fewer than #fj days remain on statute of limitations ,section #fbab is amended by adding at the end the following new subsection3 7e7 ,opportunity for appeal if fewer than #fj days remain on statute of limitations ,in the case of any issues relating to a potential deficiency with respect to which #fj days or fewer remain in the period applicable under section #feja1 if the taxpayer agrees to the extension of such period by #ab months1 the ,secretary shall issue a letter of proposed deficiency described in subsection 7a77#b77;,a77i7 allowing the taxpayer an opportunity for administrative review of such issues in the ,internal ,revenue ,service ,office of ,appeals before a notice of deficiency is issued under this section4 ,rules similar to the rules of subsection 7a77#b77;,b7 shall apply for purposes of this subsection4 4 7c7 ,effective date ,the amendments made by this section shall apply to notices of deficiency issued after the date of the enactment of this ,act4 #fjd4 ,limitation on designation of cases as not eligible for referral to ,independent ,office of ,appeals 7a7 ,in general ,if any taxpayer which is in receipt of notice of deficiency authorized under section #fbab of the ,internal ,revenue ,code of #aihf requests referral to the ,internal ,revenue ,service ,office of ,appeals and such request is denied1 the ,commissioner of ,internal ,revenue shall provide such taxpayer a written notice which-- 7#a7 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 7#b7 describes the procedures proscribed under subsection 7c7 for protesting the decision to deny the request4 7b7 ,report to ,congress ,the ,commissioner of ,internal ,revenue shall submit a written report to ,congress on an annual basis which includes the number of requests described in subsection 7a7 which were denied and the reasons 7described by category7 that such requests were denied4 7c7 ,procedures for protesting denial of request ,the ,commissioner of ,internal ,revenue shall prescribe procedures for protesting to the ,commissioner of ,internal ,revenue 7personally and not through any delegate7 a denial of a request described in subsection 7a74 7d7 ,not applicable to frivolous positions ,this section shall not apply to a request for referral to the ,internal ,revenue ,service ,office of ,appeals which is denied on the basis that the issue involved is a frivolous position 7within the meaning of section #fgjb7;c7 of the ,internal ,revenue ,code of #aihf74 #fje4 ,procedures related to ,secretarial authority to designate cases for litigation 7a7 ,in general ,chapter #gd is amended by redesignating section #gabd as section #gabe and by inserting after section #gabc the following new section3 #gabd4 ,procedures related to ,secretarial authority to designate cases for litigation 7a7 ,in general ,for any matter which the ,commissioner of ,internal ,revenue and the ,chief ,counsel for the ,internal ,revenue ,service have determined shall be designated for litigation1 such determination shall be-- 7#a7 based on a joint written recommendation by the ,commissioner of the relevant operating division of the ,internal ,revenue ,service and the ,division ,counsel for such operating division1 which shall include an explanation as to why the designation is preferable to other means of resolving the matter1 and 7#b7 made in consultation with the ,associate ,chief ,counsel with relevant subject matter jurisdiction over such matter4 7b7 ,notification prior to recommendation ,prior to submission of a recommendation described in subsection 7a77#a71 the ,division ,counsel for the relevant operating division of the ,internal ,revenue ,service shall provide written notification to the taxpayer regarding the recommendation1 including-- 7#a7 a description of the issues recommended for designation and the reasons for such recommendation1 and 7#b7 notification that the taxpayer's views may be presented in writing or in person to the ,division ,counsel and the ,commissioner of the relevant operating division-- 7,a7 within #fj days of such notification1 or 7,b7 prior to such other date as the taxpayer and the ,division ,counsel may agree4 7c7 ,notification after recommendation ,not later than #cj days after submission of a recommendation described in subsection 7a77#a71 the ,division ,counsel for the relevant operating division of the ,internal ,revenue ,service shall provide written notification to the taxpayer regarding submission of the recommendation1 including notification that the taxpayer's views may be presented in writing or in person to the ,commissioner of ,internal ,revenue and the ,chief ,counsel for the ,internal ,revenue ,service-- 7#a7 within #fj days of such notification1 or 7#b7 prior to such other date as the taxpayer1 the ,commissioner of ,internal ,revenue1 and the ,chief ,counsel for the ,internal ,revenue ,service may agree4 7d7 ,notice of approval of designation ,for any matter which the ,commissioner of ,internal ,revenue and the ,chief ,counsel for the ,internal ,revenue ,service have determined shall be designated for litigation-- 7#a7 the ,division ,counsel for the relevant operating division of the ,internal ,revenue ,service shall provide written notification to the taxpayer regarding such determination1 and 7#b7 the jurisdiction of the ,internal ,revenue ,service ,office of ,appeals over such matter shall be limited solely to any issues not included in such designation4 7e7 ,rescinding of designation ,the ,chief ,counsel for the ,internal ,revenue ,service may rescind any designation of a matter for litigation if the ,chief ,counsel determines that continuation of such litigation does not serve the purpose for which such designation was originally made4 4 7b7 ,clerical amendment ,the table of sections for chapter #gd is amended by striking the item relating to section #gabd and inserting the following new items3 ,sec4 #gabd4 ,procedures related to ,secretarial authority to designate cases for litigation4,sec4 #gabe4 ,cross references4 4 7c7 ,effective date ,the amendments made by this section shall apply to the designation of issues for litigation occurring after the date of the enactment of this ,act4 ,,vii ,miscellaneous #gja4 ,modification of authority to issue designated summons 7a7 ,in general ,paragraph 7#a7 of section #fejc7;j7 is amended by striking coordinated examination program and inserting coordinated industry case program4 7b7 ,designated summons ,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 ,large ,business and ,international ,division ,commissioner and the ,division ,counsel of the ,office of ,chief ,counsel 7or their successors7-- 7,i7 which clearly establishes that the taxpayer did not reasonably cooperate with reasonable requests by the ,secretary for witnesses1 documents1 meetings1 and interviews1 and 7,,ii7 which is attached to such summons1 4 7c7 ,burden of proof ,subsection 7j7 of section #fejc is amended by adding at the end the following new paragraph3 7#d7 ,burden of proof ,in any court proceeding described in paragraph 7#c71 the ,secretary shall bear the burden of proving that the corporation described in paragraph 7#a7 did not reasonably cooperate with reasonable requests by the ,secretary for witnesses1 documents1 meetings1 and interviews4 4 7d7 ,effective date ,the amendments made by this section shall apply to summonses issued after the date of the enactment of this ,act4 #gjb4 ,streamlined critical pay authority for information technology positions 7a7 ,authority ,section #iejc7;a7 of title #e1 ,united ,states ,code1 is amended-- 7#a7 in the matter preceding paragraph 7#a71 by striking the ,secretary of the ,treasury and all that follows through establish and inserting the ,secretary of the ,treasury may1 during the period beginning on ,october #a1 #bjah1 and ending on ,september #cj1 #bjbc1 establish1 and 7#b7 in paragraph 7#a77;,b71 by striking the ,internal ,revenue ,service's successful accomplishment of an important mission and inserting the functionality of the information technology operations of the ,internal ,revenue ,service4 7b7 ,recruitment1 retention1 relocation incentives1 and relocation expenses ,section #iejd of title #e1 ,united ,states ,code1 is amended-- 7#a7 in subsection 7a7-- 7,a7 by striking ,before ,september #cj1 #bjac and inserting ,during the period beginning on ,october #a1 #bjah1 and ending on ,september #cj1 #bjbc1 and 7,b7 by inserting for employees holding positions described in section #iejc7;a77#a7 after incentives1 and 7#b7 in subsection 7b7-- 7,a7 by striking ,before ,september #cj1 #bjac and inserting ,during the period beginning on ,october #a1 #bjah1 and ending on ,september #cj1 #bjbc1 7,b7 by striking employees transferred or reemployed and inserting employees holding positions described in section #iejc7;a77#a7 who are transferred or reemployed during such period1 and 7,c7 by striking section #iejb or #iejc after ,june #a1 #aiih and inserting section #iejc during such period4 7c7 ,performance awards for senior executives ,section #ieje7;a7 of title #e1 ,united ,states ,code1 is amended-- 7#a7 by striking ,before ,september #cj1 #bjac and inserting ,during the period beginning on ,october #a1 #bjah1 and ending on ,september #cj1 #bjbc1 and 7#b7 by striking significant functions and inserting the information technology operations4 7d7 ,effective date ,the amendments made by this section shall apply to payments made on or after the date of the enactment of this ,act4 #gjc4 ,uniform standards for the use of electronic signatures for disclosure authorizations to1 and other authorizations of1 practitioners ,paragraph 7#c7 of section #fjfa7;b7 is amended to read as follows3 7#c7 ,published guidance 7,a7 ,in general ,the ,secretary shall publish guidance as appropriate to define and implement any waiver of the signature requirements or any method adopted under paragraph 7#a74 7,b7 ,electronic signatures for disclosure authorizations to1 and other authorizations of1 practitioners ,not later than #f months after the date of the enactment of this subparagraph1 the ,secretary shall publish guidance to establish uniform standards and procedures for the acceptance of taxpayers' signatures appearing in commercially provided electronic form with respect to any request for disclosure of a taxpayer's return or return information under section #fajc7;c7 to a practitioner or any power of attorney granted by a taxpayer to a practitioner4 7,c7 ,practitioner ,for purposes of subparagraph 7,b71 the term practitioner means any individual in good standing who is regulated under section #ccj of title #ca1 ,united ,states ,code4 4 #gjd4 ,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