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S. 4964

U.S. Senate•In Senate Committee

Summary

S. 4964, the Protecting Innocent Taxpayers from Endless Assessments Act, was introduced in the Senate on Jul 14, 2026 by Sen. Roger Marshall (R) with 1 co-sponsor. It was referred to Finance, and last saw action on Jul 14, 2026: Read twice and referred to the Committee on Finance.

Record

Text

S. 4964 has 1 co-sponsor.

sb4964/introduced-in-senate.txt
119 S4964 IS: Protecting Innocent Taxpayers from Endless Assessments Act
 U.S. Senate
 2026-07-14
 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.
 II  119th CONGRESS  2d Session  S. 4964  IN THE SENATE OF THE UNITED STATES   July 14, 2026   Mr. Marshall  (for himself and  Mr. Welch ) introduced the following bill; which was read twice and referred to the  Committee on Finance    A BILL
To amend the Internal Revenue Code of 1986 to clarify that the exception to the general statute of limitations for fraudulent returns applies only when a taxpayer seeks to evade their tax obligations.
1.
Short title
This Act may be cited as the   Protecting Innocent Taxpayers from Endless Assessments Act  .
2.
Limitation period not extended for victims of preparer fraud
(a)
In general
 Section 6501(c)(1)  of the Internal Revenue Code of 1986 is amended by inserting  by the taxpayer  after  intent .
(b)
Effective date
The amendment made by this section shall apply to assessments made or proceedings begun after the date of enactment of this Act.

Tracker

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

  1. Introduced2026-07-14
  2. Passed Senate
  3. Passed House
  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.

Introduced in Senate Jul 14, 2026

sb4964/introduced-in-senate.md

Shown Here:
Introduced in Senate (07/14/2026)

Protecting Innocent Taxpayers from Endless Assessments Act

This bill limits the amount of time the Internal Revenue Service (IRS) has to assess taxes related to fraudulent or false federal tax returns where there is no intent by the taxpayer to evade taxes.

As background, the IRS generally has three years from the date that a tax return is filed (statute of limitations) to assess taxes owed by the taxpayer for the tax year. However, if a false or fraudulent tax return is filed with the intent to evade tax (fraud exception), then the IRS may assess taxes at any time. In Murrin v. Commissioner the U.S. Tax Court held (and the U.S. Court of Appeals for the Third Circuit affirmed) that the fraud exception applies when a tax return preparer places false or fraudulent entries on a tax return without the taxpayer’s knowledge. In contrast, the U.S. Court of Federal Claims held in BASR Partnership v. Commissioner that the fraud exception only applies if the taxpayer intends to evade taxes.

The bill limits the fraud exception to cases in which the taxpayer intends to evade taxes.

Sponsors

Sen. Roger Marshall (R) sponsors S. 4964, and 1 member has co-sponsored it from the day it was introduced.

Committees

S. 4964 went before 1 committee: Finance.

Finance
Finance
Referred To · Jul 14, 2026 · 902 Bills

Actions

S. 4964 has taken 2 actions since Jul 14, 2026.

ChamberAction
Jul 14, 2026
Senate
Read twice and referred to the Committee on Finance.Finance Committee
Jul 14, 2026
—
Introduced in Senate

Votes

S. 4964 has not gone to a roll call.

Titles

S. 4964 goes by 3 titles, 1 of them short titles.

  • A bill to amend the Internal Revenue Code of 1986 to clarify that the exception to the general statute of limitations for fraudulent returns applies only when a taxpayer seeks to evade their tax obligations. — Official Title as Introduced
  • Protecting Innocent Taxpayers from Endless Assessments Act — Display Title
  • Protecting Innocent Taxpayers from Endless Assessments Act — Short Title(s) as Introduced

Classification

The Congressional Research Service files S. 4964 under Taxation, one of its 31 policy areas.

CRS Subjects

CRS assigns every bill one policy area from its 31; S. 4964’s is Taxation.

s4964/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

Source: congress.gov · legiscan.com