To amend the Internal Revenue Code of 1986 to improve services provided to taxpayers by the Internal Revenue Service by providing greater judicial review.
Sponsors
Legislative Progress
Passed HouseReceived; read twice and referred to the Committee on Finance
Passed House (inferred from eh version)
Reported with an amendment, committed to the Committee of the …
Mr. Moran (for himself and Ms. Sewell) introduced the following …
Summary
What This Bill Does
The Tax Court Improvement Act modernizes U.S. Tax Court procedures to better serve taxpayers. Key changes include allowing subpoenas before hearings to facilitate settlements, expanding special trial judge authority, adding equitable tolling for missed petition deadlines, and ensuring the Tax Court remains accessible during government shutdowns.
Who Benefits and How
Taxpayers disputing IRS decisions gain significant new protections:
- Courts can now extend deadlines when taxpayers miss them due to circumstances beyond their control (equitable tolling)
- Filing deadlines are automatically extended when Tax Court offices or online portals are inaccessible (including during government shutdowns)
- Judges must recuse themselves following the same rules as other federal judges
Special trial judges can now handle more case types with party consent, reducing backlogs and speeding resolution.
Tax practitioners benefit from clearer procedures for discovery, subpoenas, and electronic filing.
Who Bears the Burden and How
The IRS faces strengthened procedural protections for taxpayers, potentially making it harder to enforce strict deadline requirements.
Tax Court administration must implement new procedures, train staff on expanded authorities, and update electronic filing systems.
Parties in Tax Court are subject to expanded pre-hearing subpoena powers for documents and electronically stored information.
Key Provisions
- Pre-hearing subpoenas authorized for discovery and settlement facilitation
- Special trial judge expansion can hear any case type with party consent
- Equitable tolling allows courts to extend filing deadlines based on circumstances
- Shutdown protection automatically tolls deadlines when Tax Court is inaccessible plus 14 additional days
- Judicial disqualification applies federal recusal standards (28 U.S.C. 455) to Tax Court
- Contempt powers for special trial judges (limited to Class C misdemeanor penalties)
Evidence Chain:
This summary is derived from the structured analysis below. See "Detailed Analysis" for per-title beneficiaries/burden bearers with clause-level evidence links.
Primary Purpose
Modernizes and expands U.S. Tax Court procedures including subpoena authority before hearings, expanded jurisdiction for special trial judges, judicial disqualification rules, equitable tolling for petition deadlines, and electronic filing provisions.
Policy Domains
Legislative Strategy
"Strengthen taxpayer protections and court efficiency by expanding judicial tools, adding equitable tolling for missed deadlines, and aligning Tax Court procedures with federal court standards"
Likely Beneficiaries
- Taxpayers in disputes with IRS (more procedural protections)
- Taxpayers who miss filing deadlines (equitable tolling)
- Tax Court (expanded tools for efficient case management)
- Special trial judges (expanded authority and contempt powers)
- Tax practitioners (clearer procedures)
Likely Burden Bearers
- IRS (facing strengthened taxpayer procedural rights)
- Tax Court administration (implementing new procedures)
- Parties in Tax Court (subject to expanded subpoena powers)
Bill Structure & Actor Mappings
Who is "The Secretary" in each section?
- "the_court"
- → United States Tax Court
- "chief_judge"
- → Chief Judge of the Tax Court
We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.
Learn more about our methodology