Small Business Taxpayer Bill of Rights Act of 2025
Summary
What This Bill Does
The bill exempts eliminates net worth limitations for 'eligible small businesses' (non-public corporations, partnerships, sole proprietorships with <$50M gross receipts) when seeking to recover legal fees and costs in tax, requires increases minimum civil damages for unauthorized disclosure of tax returns from $1,000 to $10,000 with inflation adjustment, and extends statute of limitations from 2 years to 5 years, and prohibits ex parte communications between IRS Appeals officers and other IRS employees regarding pending matters. Requires termination of employees who violate prohibition, with limited Commissioner discretion. It relies on compliance mandates, exemptions, tax deductions, and reporting requirements. The main policy areas are Tax Administration, Finance, and Labor.
Who Benefits and How
Taxpayers appealing IRS determinations could face reduced risk, Taxpayers with tax liens whose primary residence is at risk could face reduced risk, and Taxpayers whose returns were improperly disclosed could gain revenue opportunities.
Who Bears the Burden and How
IRS collection division would take on compliance duties, IRS Independent Office of Appeals would take on compliance duties, and IRS employees reviewing tax-exempt applications could face increased risk.
Key Provisions
- Exempts eliminates net worth limitations for 'eligible small businesses' (non-public corporations, partnerships, sole proprietorships with <$50M gross receipts) when seeking to recover legal fees and costs in tax...
- Requires increases minimum civil damages for unauthorized disclosure of tax returns from $1,000 to $10,000 with inflation adjustment, and extends statute of limitations from 2 years to 5 years.
- Prohibits ex parte communications between IRS Appeals officers and other IRS employees regarding pending matters. Requires termination of employees who violate prohibition, with limited Commissioner discretion...
- Exempts gives taxpayers the right to conferences with IRS Appeals that exclude personnel from Chief Counsel or IRS compliance functions unless the taxpayer specifically consents.
- Expands taxpayer access to mediation and arbitration with IRS, requires public disclosure of excluded case types, allows taxpayers to use independent non-IRS mediators, and waives mediator cost-sharing for low-income...
Evidence Chain:
This summary is generated from the full bill text using AI analysis. Expand "Detailed Analysis" below for identified beneficiaries/burden bearers with clause-level evidence links.
At a Glance
What This Bill Does
The bill exempts eliminates net worth limitations for 'eligible small businesses' (non-public corporations, partnerships, sole proprietorships with <$50M gross receipts) when seeking to recover legal fees and costs in tax, requires increases minimum civil damages for unauthorized disclosure of tax returns from $1,000 to $10,000 with inflation adjustment, and extends statute of limitations from 2 years to 5 years, and prohibits ex parte communications between IRS Appeals officers and other IRS employees regarding pending matters. Requires termination of employees who violate prohibition, with limited Commissioner discretion.
Key Policy Areas
Tax Administration, Finance, Labor
Primary Purpose
The bill exempts eliminates net worth limitations for 'eligible small businesses' (non-public corporations, partnerships, sole proprietorships with <$50M gross receipts) when seeking to recover legal fees and costs in tax, requires increases minimum civil damages for unauthorized disclosure of tax returns from $1,000 to $10,000 with inflation adjustment, and extends statute of limitations from 2 years to 5 years, and prohibits ex parte communications between IRS Appeals officers and other IRS employees regarding pending matters. Requires termination of employees who violate prohibition, with limited Commissioner discretion.
Policy Domains
Main Bill
Identified Gains
- Taxpayers appealing IRS determinations
- Taxpayers with tax liens whose primary residence is at risk
- Taxpayers whose returns were improperly disclosed
- Taxpayers seeking offers-in-compromise with the IRS
- Taxpayers seeking IRS dispute resolution
Identified Costs
- IRS collection division
- IRS Independent Office of Appeals
- IRS employees reviewing tax-exempt applications
- IRS and government employees who improperly disclose tax information
- IRS Independent Office of Appeals officers
Sponsors
Legislative Progress
In CommitteeMr. Cornyn introduced the following bill; which was read twice …
Read twice and referred to the Committee on Finance.
Introduced in Senate
Stakeholder Effects
cui bono?How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.
IRS (increased civil liability exposure), IRS (liable for more fee awards), IRS (reduced upfront collections on OIC submissions)
Individual taxpayers audited under National Research Program, Individual taxpayers audited under National Research Program with no additional tax owed, Low-income taxpayers (under 250% poverty level)
Independent mediators and arbitrators, Tax attorneys representing small businesses, Tax preparers and accountants assisting with NRP audits
Business taxpayers facing IRS levies, Small businesses with gross receipts under $50 million
Organizations applying for 501(c) tax-exempt status
Bill Structure & Actor Mappings
Who is "The Secretary" in each section?
- "the_secretary"
- → Secretary of the Treasury
- "the_commissioner"
- → Commissioner of Internal Revenue
Key Definitions
Terms defined in this bill
A corporation (not publicly traded), partnership, or sole proprietorship with gross receipts not exceeding $50 million (adjusted for inflation)
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