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H.R. 6506119th CongressTaxation
Taxpayer Due Process Enhancement Act
Sponsored by Rep. Nathaniel Moran (R-TX) · 1 active : 1 Democrat
Latest action: Received in the Senate and Read twice and referred to the Committee on Finance.
Where it standsPassed House, now in the Senate11 senators score as swing votes
Passed House
- House: passedMay 19, 2026
- Senate: next
- President: not yet
Summary
, via Congress.govTaxpayer 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.
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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.
How the projections held up
Each member’s recorded vote compared with their swing projection from before the vote. A member by voting against most of their own party.
House
Passed by voice vote or unanimous consent: no individual votes recorded.
Committees and subjects
Committees
- House Committee on Ways and Means · HouseReported by · Markup by · Referred to
- Senate Committee on Finance · SenateReferred to
Subjects
- Income tax credits
- Jurisdiction and venue
- Specialized courts
- Tax administration and collection, taxpayers
Model
Directional: count only breaks toward the other partyWhy do scores change?v3default (selected)v2 model swing-v2
How the Senate breaks down
- 11Swing 70–100
- 64Middle 30–70
- 25Entrenched 0–30
Members fall into . All 100 senators have enough data to score.
Key players in the Senate
Ranked by swing score, 0–100 · swing-v3, directional: only movement toward the other party counts, so members who sit further from the center than their party no longer score as swing votes.
Bars show each input from 0 to 100: ideology gap, scorecard gap, , and the . is the seat’s partisan lean, and shows how much of the input data a score has.
Similar past votes, Senate
Earlier behind swing-v3’s inputLoading similar votes
Cosponsors
1 activeShow all 1 cosponsors
- Terri A. Sewell (D-AL-7)
How the swing score works
Ideology gapHow far a member’s DW-NOMINATE voting score sits from their party’s median in the same chamber.
Scorecard gapHow far their Heritage Action and LCV ratings stray from their party’s average, using the groups’ votes on similar bills where available.
Cross-pressureHow strongly their district or state leans toward the other party, from our own computed partisan lean.
Similar votesHow often they voted against their own party on earlier roll calls about this bill or similar ones.
Committee bonusMembers of the committees handling the bill decide whether it moves, so they get a boost.
Cosponsor checkThe sponsor and active cosponsors have already committed, so they drop toward entrenched.
