S1386-119

In Committee

Small Business Taxpayer Bill of Rights Act of 2025

119th Congress Introduced Apr 9, 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

Tax Administration Finance Labor

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
Model: codex-gpt-5:bulk-repair | Version: bill_summary_v2 | Source: is
Taxpayers appealing IRS determinations: ,
Taxpayers seeking IRS dispute resolution:
Taxpayers whose returns were improperly disclosed:
Taxpayers seeking offers-in-compromise with the IRS:
Taxpayers with tax liens whose primary residence is at risk:
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
Model: codex-gpt-5:bulk-repair | Version: bill_summary_v2 | Source: is
IRS collection division: ,
IRS Independent Office of Appeals: ,
IRS Independent Office of Appeals officers:
IRS employees reviewing tax-exempt applications:
IRS and government employees who improperly disclose tax information:

Legislative Progress

In Committee
Introduced Committee Passed
Apr 9, 2025

Mr. Cornyn introduced the following bill; which was read twice …

Apr 9, 2025

Read twice and referred to the Committee on Finance.

Apr 9, 2025

Introduced in Senate

Stakeholder Effects

cui bono?

How this legislation distributes effects. Mention counts reflect frequency, not effect magnitude.

Government
18 mentions across 14 clauses
-17 negative ?1 uncertain

IRS (increased civil liability exposure), IRS (liable for more fee awards), IRS (reduced upfront collections on OIC submissions)

Taxpayers
13 mentions across 12 clauses
+13 positive

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)

Professional Services
3 mentions across 3 clauses
+3 positive

Independent mediators and arbitrators, Tax attorneys representing small businesses, Tax preparers and accountants assisting with NRP audits

Small Business
2 mentions across 2 clauses
+2 positive

Business taxpayers facing IRS levies, Small businesses with gross receipts under $50 million

Labor
1 mention across 1 clause
+1 positive

Employees of businesses facing IRS levies

Nonprofits
1 mention across 1 clause
+1 positive

Organizations applying for 501(c) tax-exempt status

17/19
sections analyzed
Full impact breakdown

Bill Structure & Actor Mappings

Who is "The Secretary" in each section?

Domains
Tax Administration Finance Labor
Actor Mappings
"the_secretary"
→ Secretary of the Treasury
"the_commissioner"
→ Commissioner of Internal Revenue

Key Definitions

Terms defined in this bill

1 term
"eligible small business" §2

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