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H.R. 6506

U.S. House•In Senate Committee

Summary

H.R. 6506, the Taxpayer Due Process Enhancement Act, was introduced in the House on Dec 9, 2025 by Rep. Nathaniel Moran (R) with 1 co-sponsor. It was referred to Finance, and last saw action on May 20, 2026: Received in the Senate and Read twice and referred to the Committee on Finance.

Record

Text

H.R. 6506 has 1 co-sponsor.

hb6506/engrossed-in-house.txt
119 HR 6506 EH: Taxpayer Due Process Enhancement Act
 U.S. House of Representatives
 text/xml
 EN
 Pursuant to Title 17 Section 105 of the United States Code, this file is not subject to copyright protection and is in the public domain.
 IB
 119th CONGRESS  2d Session
 H. R. 6506
 IN THE HOUSE OF REPRESENTATIVES
 AN ACT
To amend the Internal Revenue Code of 1986 to suspend the period of limitations on filing a claim for credit or refund during collection action proceedings, to prohibit the crediting of overpayments against disputed tax liability during such proceedings, and to expand the jurisdiction of the Tax Court.
1.
Short title
This Act may be cited as the   Taxpayer Due Process Enhancement Act  .
2.
Suspension of period of limitations on filing a claim for credit or refund during collection action proceedings
(a)
In general
 Section 6330(e)(1)  of the Internal Revenue Code of 1986 is amended by inserting  subsection (a), (b), or (c) of section 6511 (relating to limitations on credit or refund),  after  section 6502 (relating to collection after assessment), .
(b)
Period of limitations on filing a claim for credit or refund
Section 6330(e) of such Code is amended by adding at the end the following new paragraph:
(3)
Period of limitations on filing a claim for credit or refund
In the case of the running of any period of limitations under subsection (a), (b), or (c) of section 6511 with respect to the filing of any claim for credit or refund, paragraph (1)—
(A)
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 section, and
(B)
shall not result in a suspension of the running of such period of limitations after any date on which a lapse of a deadline, a court filing, or a court order establishes that the taxpayer has forfeited or otherwise lost the right to pursue such dispute.
 .
(c)
Cross reference
Section 6511(i) of such Code is amended by adding at the end the following new paragraph:
(8)
For limitations in case of collection action proceedings, see section 6330(e).
 .
(d)
Effective date
The amendments made by this section shall apply to the running of any period of limitations if such period (determined without regard to the amendments made by this section) ends on or after the date of the enactment of this Act.
3.
Prohibition on crediting of overpayments against disputed tax liability during collection action proceedings
(a)
In general
 Section 6402  of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection:
(o)
Prohibition on crediting of overpayments against disputed tax liability during collection action proceedings
If a hearing is properly requested under section 6320(a)(3)(B) or 6330(a)(3)(B), and an underlying tax liability referred to in section 6330(c)(2)(B) is properly disputed at such hearing, such tax liability shall not, except with the consent of the taxpayer, be taken into account under subsection (a) 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 6330(e).
 .
(b)
Clarification of application of certain levy hearing rules to lien hearings
Section 6330(c)(2)(A) of such Code is amended by striking  unpaid tax or the proposed levy  and inserting  unpaid tax, collection action, or proposed collection action .
(c)
Effective dates
(1)
In general
The amendment made by subsection (a) shall apply with respect to any period described in  section 6402(o)  of the Internal Revenue Code of 1986 (as added by this section) if any portion of such period is after the date of the enactment of this Act.
(2)
Clarification of application of certain levy hearing rules to lien hearings
The amendment made by subsection (b) shall take effect on the date of the enactment of this Act.
4.
Expansion of jurisdiction of Tax Court
(a)
In general
 Section 6330(d)(1)  of the Internal Revenue Code of 1986 is amended to read as follows:
(1)
Petition for review by Tax Court
(A)
In general
In the case of a determination under this section, the person may, within 30 days of such determination, petition the Tax Court for review of—
(i)
such determination, and
(ii)
any underlying tax liability referred to in subsection (c)(2)(B) which is properly disputed at the hearing in which such determination is made.
(B)
Jurisdiction of Tax Court
Upon the filing of a petition, the Tax Court shall have jurisdiction with respect to—
(i)
the determination referred to in subparagraph (A)(i),
(ii)
any underlying tax liability referred to in subparagraph (A)(ii), and
(iii)
any equitable tolling of the 30-day deadline referred to in subparagraph (A).
(C)
Retention of jurisdiction
Upon a determination being made under this section, subparagraphs (A) and (B) shall apply whether or not the Secretary abandons the collection action or proposed collection action at issue in such determination.
 .
(b)
Effective date
The amendment made by this section shall apply with respect to petitions filed after the date of the enactment of this Act.
    Passed the House of Representatives May 19, 2026.  Kevin F. McCumber,  Clerk.

Tracker

The tracker indicates the progress of this legislation as it moves through the legislative process.

  1. Introduced2025-12-09
  2. Passed House2026-05-19
  3. Passed Senate
  4. Conference
  5. To President
  6. Became Law

CRS Summary

The summaries are the Congressional Research Service’s, one per stage. Read them in full.

Reported to House Jan 7, 2026

hb6506/reported-to-house.md

Shown Here:
Reported to House (01/07/2026)

Taxpayer Due Process Enhancement Act

This bill suspends the period of time allowed for claiming a federal tax refund (limitations period) during collection due process (CDP) proceedings, prohibits the Internal Revenue Service (IRS) from applying tax overpayments to a tax liability that is disputed in such proceedings, and expands the Tax Court’s jurisdiction.

As background, IRS collection actions and the underlying tax liability (in some circumstances) may be disputed in a CDP hearing. Collection actions are suspended during CDP proceedings, but the IRS may apply tax overpayments from other tax years to the disputed tax liability. The Tax Court may review an appeal of a CDP hearing determination. However, the Supreme Court held in Commissioner v. Zuch that the Tax Court loses jurisdiction over a CDP appeal if the CDP hearing determination is revoked because tax overpayments are applied to and fully satisfy the tax liability. In such circumstances, the taxpayer may claim a refund and seek redress in federal district court. Currently, the limitations period to file a refund claim is not suspended during CDP proceedings.

The bill

  • suspends the limitations period for claiming a tax refund during CDP proceedings (with exceptions),
  • prohibits the IRS from applying tax overpayments to a properly disputed tax liability during CDP proceedings (unless waived or an exception applies),
  • expands the Tax Court's jurisdiction in CDP cases to include jurisdiction over the underlying tax liability amount (if properly disputed), and
  • provides that the Tax Court retains its jurisdiction if the IRS abandons collection actions.

Sponsors

Rep. Nathaniel Moran (R) sponsors H.R. 6506, and 1 member has co-sponsored it from the day it was introduced.

Committees

H.R. 6506 went before 2 committees: Finance and Ways and Means.

Finance
Finance
Referred To · May 20, 2026 · 902 Bills
Ways and Means
Ways and Means
Reported By · Jan 7, 2026 · 1,160 Bills

Reports

1 committee report has been filed on H.R. 6506, the latest H. Rept. 119-428.

Actions

H.R. 6506 has taken 13 actions since Dec 9, 2025, the latest on May 20, 2026.

ChamberAction
May 20, 2026
Senate
Received in the Senate and Read twice and referred to the Committee on Finance.Finance Committee
May 19, 202615:22
House
Mr. Smith (MO) moved to suspend the rules and pass the bill, as amended.
May 19, 202615:22
House
Considered under suspension of the rules. (consideration: CR H3564-3567)
May 19, 202615:22
House
DEBATE - The House proceeded with forty minutes of debate on H.R. 6506.
May 19, 202615:36
House
On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H3564)

Votes

H.R. 6506 has not gone to a roll call.

Titles

H.R. 6506 goes by 7 titles, 4 of them short titles.

  • Taxpayer Due Process Enhancement Act — Display Title
  • Taxpayer Due Process Enhancement Act — Short Titles from RFS (Referred to Senate) bill text
  • Taxpayer Due Process Enhancement Act — Short Title(s) as Passed House
  • To amend the Internal Revenue Code of 1986 to suspend the period of limitations on filing a claim for credit or refund during collection action proceedings, to prohibit the crediting of overpayments against disputed tax liability during such proceedings, and to expand the jurisdiction of the Tax Court. — Official Titles from EH (Engrossed in House) bill text
  • Taxpayer Due Process Enhancement Act — Short Title(s) as Reported to House
  • Taxpayer Due Process Enhancement Act — Short Title(s) as Introduced
  • To amend the Internal Revenue Code of 1986 to suspend the period of limitations on filing a claim for credit or refund during collection action proceedings, to prohibit the crediting of overpayments against disputed tax liability during such proceedings, and to expand the jurisdiction of the Tax Court. — Official Title as Introduced

Cost estimate

The Congressional Budget Office has filed 1 estimate for H.R. 6506, the latest on Feb 5, 2026.

Lobbying

2 clients hired 2 firms and 92 registered lobbyists who named H.R. 6506 in 4 quarterly filings, 2025 to 2026. Reported under the Lobbying Disclosure Act; a filing’s income covers everything its registrant worked that quarter, so the amounts below are the filings’, not this bill’s.

Filed under Small Business, Aerospace, Automotive Industry, Aviation/Airlines/Airports, Banking, Budget/Appropriations, Civil Rights/Civil Liberties, Copyright/Patent/Trademark.

Clients

Who paid to be heard, by how many filings named the bill.

ClientBusinessStateFirmsFilingsReported
SMALL BUSINESS & ENTREPRENEURSHIP COUNCIL (SBE COUNCIL)—Virginia13—
CHAMBER OF COMMERCE OF THE U.S.A.—District of Columbia11—

Firms

Registrants who filed on the bill, by filings.

RegistrantClientsFilingsReported
SMALL BUSINESS & ENTREPRENEURSHIP COUNCIL (SBE COUNCIL)13—
CHAMBER OF COMMERCE OF THE U.S.A.11—

Lobbyists

Named on the filings that cite the bill. The 20 named most often, of 92.

LobbyistFirmsClientsFilings
KAREN KERRIGAN113
RAYMOND KEATING113
ABELARDO TORRES111
ALEXA BRANSON111
AMANDA MAYS111
ANDREA PORWOLL111
ASHLEY GUM111
BRADLEY WATTS111
BRINCE MANNING111
BROOKE MILLER111
CASSIA CARVALHO111
CHAD WHITEMAN111
CHANTEL SHEAKS111
CHRISTOPHER CRENSHAW111
CHRISTOPHER EYLER111
CHRISTOPHER GUITH111
CHRISTOPHER ROBERTI111
CLARK JACKSON111
DAN BYERS111
ERIN DELANEY111

Filings

The documents themselves, on the Senate’s Lobbying Disclosure site, largest reported first.

ClientRegistrantPeriodReportedDocument
CHAMBER OF COMMERCE OF THE U.S.A.CHAMBER OF COMMERCE OF THE U.S.A.2025 fourth_quarter$18M4th Quarter - Report
SMALL BUSINESS & ENTREPRENEURSHIP COUNCIL (SBE COUNCIL)SMALL BUSINESS & ENTREPRENEURSHIP COUNCIL (SBE COUNCIL)2026 second_quarter$45K2nd Quarter - Report
SMALL BUSINESS & ENTREPRENEURSHIP COUNCIL (SBE COUNCIL)SMALL BUSINESS & ENTREPRENEURSHIP COUNCIL (SBE COUNCIL)2026 first_quarter$35K1st Quarter - Report
SMALL BUSINESS & ENTREPRENEURSHIP COUNCIL (SBE COUNCIL)SMALL BUSINESS & ENTREPRENEURSHIP COUNCIL (SBE COUNCIL)2025 fourth_quarter$30K4th Quarter - Report

Classification

The Congressional Research Service files H.R. 6506 under Taxation, one of its 31 policy areas, and gives it 4 legislative subjects.

CRS Subjects

CRS assigns every bill one policy area from its 31; H.R. 6506’s is Taxation.

hr6506/policy-areas.txt
TaxationAgriculture and FoodAnimalsArmed Forces and National SecurityArts, Culture, ReligionCivil Rights and Liberties, Minority IssuesCommerceCongressCrime and Law EnforcementEconomics and Public FinanceEducationEmergency ManagementEnergyEnvironmental ProtectionFamiliesFinance and Financial SectorForeign Trade and International FinanceGovernment Operations and PoliticsHealthHousing and Community DevelopmentImmigrationInternational AffairsLabor and EmploymentLawNative AmericansPublic Lands and Natural ResourcesScience, Technology, CommunicationsSocial WelfareSports and RecreationTransportation and Public WorksWater Resources Development

Legislative Subjects

H.R. 6506 carries 4 of CRS’s legislative subjects, from Income tax credits to Tax administration and collection, taxpayers.

hr6506/subjects.txt
Income tax creditsJurisdiction and venueSpecialized courtsTax administration and collection, taxpayers

Constitutional authority

The clause the sponsor cites as Congress’s power to enact H.R. 6506, as entered in the Congressional Record.

[Congressional Record Volume 171, Number 207 (Tuesday, December 9, 2025)][House]From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]By Mr. MORAN:H.R. 6506.Congress has the power to enact this legislation pursuantto the following:Article I, Section 8[Page H5112]

Source: congress.gov · legiscan.com