,,ib ,union ,calendar ,no4 #cgc #aaith ,,congress #b;d ,session ,h4 ,r4 #fejf ,report ,no4 #aai-dbh ,,in ,,the ,,house ,,of ,,representatives ,december #i1 #bjbe,mr4 ,moran 7for himself and ,ms4 ,sewell7 introduced the following bill2 which was referred to the ,committee on ,ways and ,means ,january #g1 #bjbf,reported with an amendment1 committed to the ,committee of the ,whole ,house on the ,state of the ,union1 and ordered to be printed,strike out all after the enacting clause and insert the part printed in italic,for text of introduced bill1 see copy of bill as introduced on ,december #i1 #bjbe ,a ,,bill ,to amend the ,internal ,revenue ,code of #aihf to suspend the period of limitations on filing a claim for credit or refund during collection action proceedings1 to prohibit the crediting of overpayments against disputed tax liability during such proceedings1 and to expand the jurisdiction of the ,tax ,court4 #a4 ,short title ,this ,act may be cited as the ,taxpayer ,due ,process ,enhancement ,act4 #b4 ,suspension of period of limitations on filing a claim for credit or refund during collection action proceedings 7a7 ,in general ,section #fccj7;e77#a7 of the ,internal ,revenue ,code of #aihf is amended by inserting subsection 7a71 7b71 or 7c7 of section #feaa 7relating to limitations on credit or refund71 after section #fejb 7relating to collection after assessment714 7b7 ,period of limitations on filing a claim for credit or refund ,section #fccj7;e7 of such ,code is amended by adding at the end the following new paragraph3 7#c7 ,period of limitations on filing a claim for credit or refund ,in the case of the running of any period of limitations under subsection 7a71 7b71 or 7c7 of section #feaa with respect to the filing of any claim for credit or refund1 paragraph 7#a7-- 7,a7 shall apply only to the extent that such credit or refund relates to an underlying tax liability properly disputed at the hearing requested under this section1 and 7,b7 shall not result in a suspension of the running of such period of limitations after any date on which a lapse of a deadline1 a court filing1 or a court order establishes that the taxpayer has forfeited or otherwise lost the right to pursue such dispute4 4 7c7 ,cross reference ,section #feaa7;i7 of such ,code is amended by adding at the end the following new paragraph3 7#h7 ,for limitations in case of collection action proceedings1 see section #fccj7;e74 4 7d7 ,effective date ,the amendments made by this section shall apply to the running of any period of limitations if such period 7determined without regard to the amendments made by this section7 ends on or after the date of the enactment of this ,act4 #c4 ,prohibition on crediting of overpayments against disputed tax liability during collection action proceedings 7a7 ,in general ,section #fdjb of the ,internal ,revenue ,code of #aihf is amended by adding at the end the following new subsection3 7o7 ,prohibition on crediting of overpayments against disputed tax liability during collection action proceedings ,if a hearing is properly requested under section #fcbj7;a77#c77;,b7 or #fccj7;a77#c77;,b71 and an underlying tax liability referred to in section #fccj7;c77#b77;,b7 is properly disputed at such hearing1 such tax liability shall not1 except with the consent of the taxpayer1 be taken into account under subsection 7a7 for the period during which the period of limitations for filing a claim for credit or refund relating to such tax liability is suspended by reason of section #fccj7;e74 4 7b7 ,clarification of application of certain levy hearing rules to lien hearings ,section #fccj7;c77#b77;,a7 of such ,code is amended by striking unpaid tax or the proposed levy and inserting unpaid tax1 collection action1 or proposed collection action4 7c7 ,effective dates 7#a7 ,in general ,the amendment made by subsection 7a7 shall apply with respect to any period described in section #fdjb7o7 of the ,internal ,revenue ,code of #aihf 7as added by this section7 if any portion of such period is after the date of the enactment of this ,act4 7#b7 ,clarification of application of certain levy hearing rules to lien hearings ,the amendment made by subsection 7b7 shall take effect on the date of the enactment of this ,act4 #d4 ,expansion of jurisdiction of ,tax ,court 7a7 ,in general ,section #fccj7;d77#a7 of the ,internal ,revenue ,code of #aihf is amended to read as follows3 7#a7 ,petition for review by ,tax ,court 7,a7 ,in general ,in the case of a determination under this section1 the person may1 within #cj days of such determination1 petition the ,tax ,court for review of-- 7i7 such determination1 and 7ii7 any underlying tax liability referred to in subsection 7c77#b77;,b7 which is properly disputed at the hearing in which such determination is made4 7,b7 ,jurisdiction of ,tax ,court ,upon the filing of a petition1 the ,tax ,court shall have jurisdiction with respect to-- 7i7 the determination referred to in subparagraph 7,a77i71 7ii7 any underlying tax liability referred to in subparagraph 7,a77ii71 and 7iii7 any equitable tolling of the #cj-;day deadline referred to in subparagraph 7,a74 7,c7 ,retention of jurisdiction ,upon a determination being made under this section1 subparagraphs 7,a7 and 7,b7 shall apply whether or not the ,secretary abandons the collection action or proposed collection action at issue in such determination4 4 7b7 ,effective date ,the amendment made by this section shall apply with respect to petitions filed after the date of the enactment of this ,act4 ,january #g1 #bjbf,reported with an amendment1 committed to the ,committee of the ,whole ,house on the ,state of the ,union1 and ordered to be printed