3.0.0 4964 2026-07-31T12:43:02Z 2026-07-31T12:43:02Z Senate S S 2026-07-14 119 https://www.congress.gov/bill/119th-congress/senate-bill/4964 ssfi00 Finance Committee Senate Standing Referred To 2026-07-14T15:42:41Z 2026-07-14 ssfi00 Finance Committee Senate Read twice and referred to the Committee on Finance. IntroReferral 2026-07-14 Introduced in Senate IntroReferral 10000 9 Library of Congress M001198 Sen. Marshall, Roger [R-KS] Roger Marshall R KS N W000800 Sen. Welch, Peter [D-VT] Peter Welch D VT 2026-07-14 True Taxation Taxation 2026-07-29T22:32:59Z 00 2026-07-14 Introduced in Senate 2026-07-31T12:41:13Z 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.

]]> Protecting Innocent Taxpayers from Endless Assessments Act Official Title as Introduced 6 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. 2026-07-18T22:06:14Z Introduced in Senate IS Display Title 45 Protecting Innocent Taxpayers from Endless Assessments Act 2026-07-18T11:56:05Z Short Title(s) as Introduced 101 Protecting Innocent Taxpayers from Endless Assessments Act 2026-07-18T11:53:34Z Introduced in Senate IS Introduced in Senate 2026-07-14T04:00:00Z https://www.govinfo.gov/content/pkg/BILLS-119s4964is/xml/BILLS-119s4964is.xml 2026-07-14 Read twice and referred to the Committee on Finance. 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. Congressional Research Service, Library of Congress This file contains bill summaries and statuses for federal legislation. A bill summary describes the most significant provisions of a piece of legislation and details the effects the legislative text may have on current law and federal programs. Bill summaries are authored by the Congressional Research Service (CRS) of the Library of Congress. As stated in Public Law 91-510 (2 USC 166 (d)(6)), one of the duties of CRS is "to prepare summaries and digests of bills and resolutions of a public general nature introduced in the Senate or House of Representatives". For more information, refer to the User Guide that accompanies this file.