[Congressional Bills 106th Congress]
[From the U.S. Government Publishing Office]
[H.R. 4163 Engrossed in House (EH)]


  2d Session

                               H. R. 4163

_______________________________________________________________________

                                 AN ACT

  To amend the Internal Revenue Code of 1986 to provide for increased 
                         fairness to taxpayers.
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
106th CONGRESS
  2d Session
                                H. R. 4163

_______________________________________________________________________

                                 AN ACT


 
  To amend the Internal Revenue Code of 1986 to provide for increased 
                         fairness to taxpayers.

    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE; ETC.

    (a) Short Title.--This Act may be cited as the ``Taxpayer Bill of 
Rights 2000''.
    (b) Amendment of 1986 Code.--Except as otherwise expressly 
provided, whenever in this Act an amendment or repeal is expressed in 
terms of an amendment to, or repeal of, a section or other provision, 
the reference shall be considered to be made to a section or other 
provision of the Internal Revenue Code of 1986.
    (c) Table of Contents.--

Sec. 1. Short title; etc.
                    TITLE I--PENALTIES AND INTEREST

Sec. 101. Failure to pay estimated tax penalty converted to interest 
                            charge on accumulated unpaid balance.
Sec. 102. Exclusion from gross income for interest on overpayments of 
                            income tax by individuals.
Sec. 103. Reductions of penalty for failure to pay tax.
Sec. 104. Abatement of interest.
Sec. 105. Deposits made to stop the running of interest on potential 
                            underpayments.
Sec. 106. Expansion of interest netting for individuals.
                TITLE II--CONFIDENTIALITY AND DISCLOSURE

Sec. 201. Disclosure and privacy rules relating to returns and return 
                            information.
Sec. 202. Expansion of type of advice available for public inspection.
Sec. 203. Collection activities with respect to joint return 
                            disclosable to either spouse based on oral 
                            request.
Sec. 204. Taxpayer representatives not subject to examination on sole 
                            basis of representation of taxpayers.
Sec. 205. Disclosure in judicial or administrative tax proceedings of 
                            return and return information of persons 
                            who are not party to such proceedings.
Sec. 206. Prohibition of disclosure of taxpayer identification 
                            information with respect to disclosure of 
                            accepted offers-in-compromise.
Sec. 207. Compliance by State contractors with confidentiality 
                            safeguards.
Sec. 208. Higher standards for requests for and consents to disclosure.
Sec. 209. Notice to taxpayer concerning administrative determination of 
                            browsing; annual report.
Sec. 210. Disclosure of taxpayer identity for tax refund purposes.
                     TITLE III--OTHER REQUIREMENTS

Sec. 301. Clarification of definition of church tax inquiry.
Sec. 302. Expansion of declaratory judgment remedy to tax-exempt 
                            organizations.
Sec. 303. Employee misconduct report to include summary of complaints 
                            by category.
Sec. 304. Increase in threshold for Joint Committee reports on refunds 
                            and credits.
Sec. 305. Annual report on awards of costs and certain fees in 
                            administrative and court proceedings.
Sec. 306. Annual report on abatement of penalties.
Sec. 307. Better means of communicating with taxpayers.
Sec. 308. Explanation of statute of limitations and consequences of 
                            failure to file.

                    TITLE I--PENALTIES AND INTEREST

SEC. 101. FAILURE TO PAY ESTIMATED TAX PENALTY CONVERTED TO INTEREST 
              CHARGE ON ACCUMULATED UNPAID BALANCE.

    (a) Penalty Moved to Interest Chapter of Code.--The Internal 
Revenue Code of 1986 is amended by redesignating section 6654 as 
section 6641 and by moving section 6641 (as so redesignated) from part 
I of subchapter A of chapter 68 to the end of subchapter E of chapter 
67 (as added by subsection (e)(1) of this section).
    (b) Penalty Converted to Interest Charge.--The heading and 
subsections (a) and (b) of section 6641 (as so redesignated) are 
amended to read as follows:

``SEC. 6641. INTEREST ON FAILURE BY INDIVIDUAL TO PAY ESTIMATED INCOME 
              TAX.

    ``(a) In General.--Interest shall be paid on any underpayment of 
estimated tax by an individual for a taxable year for each day of such 
underpayment. The amount of such interest for any day shall be the 
product of the underpayment rate established under subsection (b)(2) 
multiplied by the amount of the underpayment.
    ``(b) Amount of Underpayment; Interest Rate.--For purposes of 
subsection (a)--
            ``(1) Amount.--The amount of the underpayment on any day 
        shall be the excess of--
                    ``(A) the sum of the required installments for the 
                taxable year the due dates for which are on or before 
                such day, over
                    ``(B) the sum of the amounts (if any) of estimated 
                tax payments made on or before such day on such 
                required installments.
            ``(2) Determination of interest rate.--
                    ``(A) In general.--The underpayment rate with 
                respect to any day in an installment underpayment 
                period shall be the underpayment rate established under 
                section 6621 for the first day of the calendar quarter 
                in which such installment underpayment period begins.
                    ``(B) Installment underpayment period.--For 
                purposes of subparagraph (A), the term `installment 
                underpayment period' means the period beginning on the 
                day after the due date for a required installment and 
                ending on the due date for the subsequent required 
                installment (or in the case of the 4th required 
                installment, the 15th day of the 4th month following 
                the close of a taxable year).
                    ``(C) Daily rate.--The rate determined under 
                subparagraph (A) shall be applied on a daily basis and 
                shall be based on the assumption of 365 days in a 
                calendar year.
            ``(3) Termination of estimated tax interest.--No day after 
        the end of the installment underpayment period for the 4th 
        required installment specified in paragraph (2)(B) for a 
        taxable year shall be treated as a day of underpayment with 
        respect to such taxable year.''.
    (c) Increase in Safe Harbor Where Tax is Small.--
            (1) In general.--Clause (i) of section 6641(d)(1)(B) (as so 
        redesignated) is amended to read as follows:
                            ``(i) the lesser of--
                                    ``(I) 90 percent of the tax shown 
                                on the return for the taxable year (or, 
                                if no return is filed, 90 percent of 
                                the tax for such year), or
                                    ``(II) the tax shown on the return 
                                for the taxable year (or, if no return 
                                is filed, the tax for such year) 
                                reduced (but not below zero) by $2,000, 
                                or''.
            (2) Conforming amendment.--Subsection (e) of section 6641 
        (as so redesignated) is amended by striking paragraph (1) and 
        redesignating paragraphs (2) and (3) as paragraphs (1) and (2), 
        respectively.
    (d) Conforming Amendments.--
            (1) Paragraphs (1) and (2) of subsection (e) (as 
        redesignated by subsection (c)(2)) and subsection (h) of 
        section 6641 (as so designated) are each amended by striking 
        ``addition to tax'' each place it occurs and inserting 
        ``interest''.
            (2) Section 167(g)(5)(D) is amended by striking ``6654'' 
        and inserting ``6641''.
            (3) Section 460(b)(1) is amended by striking ``6654'' and 
        inserting ``6641''.
            (4) Section 3510(b) is amended--
                    (A) by striking ``section 6654'' in paragraph (1) 
                and inserting ``section 6641'';
                    (B) by amending paragraph (2)(B) to read as 
                follows:
                    ``(B) no interest would be required to be paid (but 
                for this section) under 6641 for such taxable year by 
                reason of the $2,000 amount specified in section 
                6641(d)(1)(B)(i)(II).'';
                    (C) by striking ``section 6654(d)(2)'' in paragraph 
                (3) and inserting ``section 6641(d)(2)''; and
                    (D) by striking paragraph (4).
            (5) Section 6201(b)(1) is amended by striking ``6654'' and 
        inserting ``6641''.
            (6) Section 6601(h) is amended by striking ``6654'' and 
        inserting ``6641''.
            (7) Section 6621(b)(2)(B) is amended by striking ``addition 
        to tax under section 6654'' and inserting ``interest required 
        to be paid under section 6641''.
            (8) Section 6622(b) is amended--
                    (A) by striking ``Penalty for'' in the heading; and
                    (B) by striking ``addition to tax under section 
                6654 or 6655'' and inserting ``interest required to be 
                paid under section 6641 or addition to tax under 
                section 6655''.
            (9) Section 6658(a) is amended--
                    (A) by striking ``6654, or 6655'' and inserting 
                ``or 6655, and no interest shall be required to be paid 
                under section 6641,''; and
                    (B) by inserting ``or paying interest'' after ``the 
                tax'' in paragraph (2)(B)(ii).
            (10) Section 6665(b) is amended--
                    (A) in the matter preceding paragraph (1) by 
                striking ``, 6654,''; and
                    (B) in paragraph (2) by striking ``6654 or''.
            (11) Section 7203 is amended by striking ``section 6654 or 
        6655'' and inserting ``section 6655 or interest required to be 
        paid under section 6641''.
    (e) Clerical Amendments.--
            (1) Chapter 67 is amended by inserting after subchapter D 
        the following:

  ``Subchapter E--Interest on Failure by Individual to Pay Estimated 
                               Income Tax

                              ``Sec. 6641. Interest on failure by 
                                        individual to pay estimated 
                                        income tax.''.
            (2) The table of subchapters for chapter 67 is amended by 
        adding at the end the following new items:

                              ``Subchapter D. Notice requirements.
                              ``Subchapter E. Interest on failure by 
                                        individual to pay estimated 
                                        income tax.''.
            (3) The table of sections for part I of subchapter A of 
        chapter 68 is amended by striking the item relating to section 
        6654.
    (f) Effective Date.--The amendments made by this section shall 
apply to installment payments for taxable years beginning after 
December 31, 2000.

SEC. 102. EXCLUSION FROM GROSS INCOME FOR INTEREST ON OVERPAYMENTS OF 
              INCOME TAX BY INDIVIDUALS.

    (a) In General.--Part III of subchapter B of chapter 1 (relating to 
items specifically excluded from gross income) is amended by 
redesignating section 139 as section 139A and by inserting after 
section 138 the following new section:

``SEC. 139. EXCLUSION FROM GROSS INCOME FOR INTEREST ON OVERPAYMENTS OF 
              INCOME TAX BY INDIVIDUALS.

    ``(a) In General.--In the case of an individual, gross income shall 
not include interest paid under section 6611 on any overpayment of tax 
imposed by this subtitle.
    ``(b) Exception.--Subsection (a) shall not apply in the case of a 
failure to claim items resulting in the overpayment on the original 
return if the Secretary determines that the principal purpose of such 
failure is to take advantage of subsection (a).
    ``(c) Special Rule for Determining Modified Adjusted Gross 
Income.--For purposes of this title, interest not included in gross 
income under subsection (a) shall not be treated as interest which is 
exempt from tax for purposes of sections 32(i)(2)(B) and 6012(d) or any 
computation in which interest exempt from tax under this title is added 
to adjusted gross income.''.
    (b) Clerical Amendment.--The table of sections for part III of 
subchapter B of chapter 1 is amended by striking the item relating to 
section 139 and inserting the following new items:

                              ``Sec. 139. Exclusion from gross income 
                                        for interest on overpayments of 
                                        income tax by individuals.
                              ``Sec. 139A. Cross references to other 
                                        Acts.''.
    (c) Effective Date.--The amendments made by this section shall 
apply to interest received in calendar years beginning after the date 
of the enactment of this Act.

SEC. 103. REDUCTIONS OF PENALTY FOR FAILURE TO PAY TAX.

    (a) Reductions of Penalty for Failure To Pay Tax.--
            (1) Reduction of penalty by 50 percent.--
                    (A) In general.--Paragraphs (2) and (3) of section 
                6651(a) are each amended by striking ``0.5'' each place 
                it appears and inserting ``0.25''.
                    (B) Conforming amendment.--Paragraph (1) of section 
                6651(d) is amended by striking ``by substituting `1 
                percent' for `0.5 percent''' and inserting ``by 
                substituting `0.5 percent' for `0.25 percent'''.
            (2) Reduction of penalty to zero during period of 
        installment agreement.--Subsection (h) of section 6651 is 
        amended by striking ``by substituting `0.25' for `0.5''' and 
        inserting ``by substituting `zero' for `0.25'''.
            (3) Effective date.--The amendments made by this subsection 
        shall apply for purposes of determining additions to tax for 
        months beginning after December 31, 2000.
    (b) Prohibition of Fee for Installment Agreements Using Automated 
Withdrawals.--
            (1) In general.--Section 6159 (relating to agreements for 
        payment of tax liability in installments) is amended by 
        redesignating subsection (e) as subsection (f) and by inserting 
        after subsection (d) the following new subsection:
    ``(e) Prohibition of Fee for Installment Agreements Using Automated 
Withdrawals.--The Secretary may not charge a taxpayer a fee for 
entering into an agreement with the Secretary under this section only 
for so long as payments under such agreement are made by means of 
electronic transfer or by similar automated means.''.
            (2) Effective date.--The amendments made by this subsection 
        shall apply to installment agreements entered into more than 30 
        days after the date of the enactment of this Act.

SEC. 104. ABATEMENT OF INTEREST.

    (a) Abatement of Interest if Gross Injustice Would Otherwise 
Result.--Section 6404 is amended by redesignating subsection (i) as 
subsection (j) and by inserting after subsection (h) the following new 
subsection:
    ``(i) Abatement of Interest if Gross Injustice Would Otherwise 
Result.--The Secretary may abate the assessment of all or any part of 
interest on any amount of tax imposed by this title for any period if 
the Secretary determines that--
            ``(1) a gross injustice would otherwise result if interest 
        were to be charged, and
            ``(2) no significant aspect of the events giving rise to 
        the accrual of the interest can be attributed to the taxpayer 
        involved.''.
    (b) Abatement of Interest for Periods Attributable to Any 
Unreasonable IRS Error or Delay.--Subparagraphs (A) and (B) of section 
6404(e)(1) are each amended by striking ``in performing a ministerial 
or managerial act''.
    (c) Abatement of Interest With Respect to Erroneous Refund Check 
Without Regard to Size of Refund.--Paragraph (2) of section 6404(e) is 
amended by striking ``unless--'' and all that follows and inserting 
``unless the taxpayer (or a related party) has in any way caused such 
erroneous refund.''.
    (d) Abatement of Interest to Extent Interest is Attributable to 
Taxpayer Reliance on Written Statements of the IRS.--Subsection (f) of 
section 6404 is amended--
            (1) in the subsection heading, by striking ``Penalty or 
        Addition'' and inserting ``Interest, Penalty, or Addition''; 
        and
            (2) in paragraph (1) and in subparagraph (B) of paragraph 
        (2), by striking ``penalty or addition'' and inserting 
        ``interest, penalty, or addition''.
    (e) Effective Date.--The amendments made by this section shall 
apply with respect to interest accruing on or after the date of the 
enactment of this Act.

SEC. 105. DEPOSITS MADE TO STOP THE RUNNING OF INTEREST ON POTENTIAL 
              UNDERPAYMENTS.

    (a) In General.--Subchapter B of chapter 67 (relating to interest 
on overpayments) is amended by redesignating section 6612 as section 
6613 and by inserting after section 6611 the following new section:

``SEC. 6612. DEPOSITS MADE TO STOP THE RUNNING OF INTEREST ON POTENTIAL 
              UNDERPAYMENTS, ETC.

    ``(a) Authority To Make Deposits Other Than As Payment of Tax.--Any 
taxpayer may make a cash bond deposit with the Secretary to offset any 
potential underpayment of tax imposed by this title for any taxable 
period. Such a deposit shall be made in such manner as the Secretary 
shall prescribe.
    ``(b) Deposits Used To Pay Underpayment Also Offset Running of 
Interest on Underpayment.--Any cash bond deposit used to pay tax under 
this title shall offset interest under subchapter A during the period 
of such deposit on such tax under such procedures as the Secretary 
shall prescribe.
    ``(c) Taxpayer May Request Return of Cash Bond Deposit.--
            ``(1) In general.--On written request of a taxpayer who 
        made a cash bond deposit, the Secretary shall return to the 
        taxpayer any amount of such deposit specified by the taxpayer.
            ``(2) No interest.--In the case of a deposit which is so 
        returned--
                    ``(A) the amount returned shall not offset interest 
                under subchapter A for any period, and
                    ``(B) except as provided in subsection (d), no 
                interest shall be allowed on such amount.
            ``(3) Exceptions.--Paragraph (1) shall not apply to any 
        amount if--
                    ``(A) such amount has been treated by the Secretary 
                as a payment of tax after a final determination of the 
                disputed items to which such amount relates,
                    ``(B) such amount has been designated by the 
                taxpayer as being a payment of tax,
                    ``(C) the Secretary determines that assessment or 
                collection of tax is in jeopardy, or
                    ``(D) the amount is applied in accordance with 
                section 6402.
        Subparagraph (D) shall not apply to a payment to a taxpayer if 
        the taxpayer is entitled to be paid interest under subsection 
        (d) on such payment.
    ``(d) Interest on Amounts Returned in Certain Circumstances.--
            ``(1) In general.--Interest shall be allowed and paid on 
        the amount of any cash bond deposit for a taxable period which 
        is returned to the taxpayer only if the deposit is attributable 
        to a dispute reserve account for such period.
            ``(2) Attribution to dispute reserve account.--For purposes 
        of paragraph (1), an amount is attributable to a dispute 
        reserve account for any taxable period only to the extent that 
        the aggregate of the cash bond deposits for such period 
        (reduced by the amount of such deposits which has been 
        previously returned to the taxpayer or treated as a payment of 
        tax) does not exceed the deposit limit for such period.
            ``(3) Deposit limit.--For purposes of paragraph (2)--
                    ``(A) In general.--The deposit limit for any 
                taxable period is the amount specified by the taxpayer 
                at the time of the deposit as the taxpayer's reasonable 
                estimate of the potential underpayment for such period 
                with respect to disputable items identified (at such 
                time) by the taxpayer with respect to such deposit.
                    ``(B) Safe harbor based on 30-day letter.--In the 
                case of a taxpayer who is issued a 30-day letter for 
                any taxable period, the deposit limit for such period 
                shall not be less than the amount of the proposed 
                deficiency specified in such letter.
            ``(4) Definitions.--For purposes of paragraph (3)--
                    ``(A) Disputable item.--The term `disputable item' 
                means any item if the taxpayer--
                            ``(i) has a reasonable basis for its 
                        treatment of such item, and
                            ``(ii) reasonably believes that the 
                        Secretary also has a reasonable basis for 
                        disallowing the taxpayer's treatment of such 
                        item.
                    ``(B) 30-day letter.--The term `30-day letter' 
                means the first letter of proposed deficiency which 
                allows the taxpayer an opportunity for administrative 
                review in the Internal Revenue Service Office of 
                Appeals.
            ``(5) Rate and period of interest.--
                    ``(A) Rate.--The rate of interest allowable under 
                this subsection shall be the Federal short-term rate 
                determined under section 6621(b), compounded daily.
                    ``(B) Period.--Interest under this subsection on 
                any payment to a taxpayer shall be payable from the 
                date of the deposit to which such payment is 
                attributable to a date (to be determined by the 
                Secretary) preceding the date of the check making such 
                payment by not more than 30 days. For purposes of the 
                preceding sentence, cash bond deposits for any taxable 
                period shall be treated as used and returned on a last-
                in first-out basis.
    ``(e) Cash Bond Deposit.--For purposes of this section--
            ``(1) In general.--The term `cash bond deposit' means any 
        payment which is designated by the taxpayer as being a cash 
        bond deposit for a specified taxable period.
            ``(2) Amounts designated or used as payment of tax.--A cash 
        bond deposit shall cease to be treated as such for purposes of 
        this section beginning on the date that the taxpayer designates 
        such deposit as a payment of tax for purposes of this title, 
        or, if earlier, on the date such deposit is so used.
    ``(f) Change in Period for Which Deposit Made.--Subject to the 
requirements of subsection (d), a taxpayer may change the taxable 
period to which a cash bond deposit relates.''.
    (b) Clerical Amendment.--The table of sections for subchapter B of 
chapter 67 is amended by striking the last item and inserting the 
following new items:

                              ``Sec. 6612. Deposits made to stop the 
                                        running of interest on 
                                        potential underpayments, etc.
                              ``Sec. 6613. Cross references.''.
    (c) Effective Date.--
            (1) In general.--The amendments made by this section shall 
        apply to interest for periods after the date of the enactment 
        of this Act.
            (2) Specification of disputed items.--In the case of 
        amounts held by the Secretary of the Treasury on the date of 
        the enactment of this Act as a deposit in the nature of a cash 
        bond pursuant to Revenue Procedure 84-58, the date that the 
        taxpayer makes the identification under subsection (d)(3)(A) of 
        section 6612 of the Internal Revenue Code of 1986, as added by 
        this section, shall be treated as the date such amounts were 
        deposited for purposes of such section 6612.

SEC. 106. EXPANSION OF INTEREST NETTING FOR INDIVIDUALS.

    (a) In General.--Subsection (d) of section 6621 (relating to 
elimination of interest on overlapping periods of tax overpayments and 
underpayments) is amended by adding at the end the following: ``Solely 
for purposes of the preceding sentence, section 6611(e) shall not apply 
in the case of an individual.''.
    (b) Effective Date.--The amendment made by subsection (a) shall 
apply to interest accrued after December 31, 2000.

                TITLE II--CONFIDENTIALITY AND DISCLOSURE

SEC. 201. DISCLOSURE AND PRIVACY RULES RELATING TO RETURNS AND RETURN 
              INFORMATION.

    (a) In General.--Subsection (a) of section 6103 (relating to 
general rule for confidentiality and disclosure of returns and return 
information) is amended by striking ``title--'' and inserting ``title 
and notwithstanding any other provision of law--''.
    (b) Procedural and Jurisdictional Rules.--Subsection (p) of section 
6103 (relating to procedure and recordkeeping) is amended by adding at 
the end the following new paragraph:
            ``(9) Procedural rules applicable to certain disclosures.--
                    ``(A) In general.--The Secretary shall prescribe 
                regulations for purposes of providing for disclosures 
                of return and return information under subsections (c), 
                (e), and (k)(1) and (2). Such regulations shall include 
                a schedule of fees, and waivers and reductions of such 
                fees, applicable to the processing of requests for such 
                disclosures.
                    ``(B) Determinations of whether to comply with 
                disclosure requests.--
                            ``(i) Initial requests.--In response to a 
                        request that reasonably describes the return or 
                        return information sought and is made in 
                        accordance with the published rules, the 
                        Secretary shall--
                                    ``(I) determine within 20 days 
                                after the receipt of any request for 
                                disclosure of return or return 
                                information under subsections (c), (e), 
                                and (k)(1) and (2) whether to comply 
                                with such request, and
                                    ``(II) immediately notify the 
                                person making such request of such 
                                determination and the reasons therefor, 
                                and of the right of such person to 
                                appeal to the Commissioner any adverse 
                                determination.
                            ``(ii) Appeal.--The Commissioner shall--
                                    ``(I) make a determination with 
                                respect to any appeal of any adverse 
                                determination under clause (i)(I) 
                                within 20 days after the receipt of 
                                such appeal, and
                                    ``(II) if on appeal the denial of 
                                the request for disclosure of such 
                                return or return information is in 
                                whole or in part upheld, the 
                                Commissioner shall notify the person 
                                making such request of the provisions 
                                for judicial review of that 
                                determination under subparagraph (D).
                            ``(iii) Extension of periods for unusual 
                        circumstances.--
                                    ``(I) In general.--The time limits 
                                prescribed in clause (i) and clause 
                                (ii) (as the case may be) may be 
                                extended for not more than 10 days in 
                                unusual circumstances by providing to 
                                the person making such request for 
                                disclosure written notice which sets 
                                forth the unusual circumstances for 
                                such extension and the date on which a 
                                determination is expected to be 
                                dispatched. No such notice shall 
                                specify a date that would result in an 
                                extension for more than 10 working 
                                days, except as provided in subclause 
                                (II).
                                    ``(II) Modification of request or 
                                time period.--If, with respect to a 
                                request for which the time limits are 
                                extended under subclause (I), the 
                                Secretary determines that the request 
                                cannot be processed within the time 
                                limit so specified, the Secretary shall 
                                notify the person making the request 
                                and shall provide the person an 
                                opportunity to limit the scope of the 
                                request so that it may be processed 
                                within that time limit or an 
                                opportunity to arrange with the agency 
                                an alternative time frame for 
                                processing the request or a modified 
                                request. Refusal by the person to 
                                reasonably modify the request or 
                                arrange such an alternative time frame 
                                shall be considered as a factor in 
                                determining whether exceptional 
                                circumstances exist for purposes of 
                                subparagraph (C).
                            ``(iv) Unusual circumstances defined.--For 
                        purposes of clause (iii), the term `unusual 
                        circumstances' means, but only to the extent 
                        reasonably necessary to the proper processing 
                        of the particular requests--
                                    ``(I) the need to search for and 
                                collect the requested records from 
                                field facilities or other 
                                establishments that are separate from 
                                the office processing the request,
                                    ``(II) the need to search for, 
                                collect, and appropriately examine a 
                                voluminous amount of separate and 
                                distinct records which are demanded in 
                                a single request, or
                                    ``(III) the need for consultation, 
                                which shall be conducted with all 
                                practicable speed, with another agency 
                                having a substantial interest in the 
                                determination of the request or among 
                                two or more components of the agency 
                                having substantial subject-matter 
                                interest therein.
                            ``(v) 20-day period excludes certain 
                        days.--The 20-day periods referred to in 
                        clauses (i) and (ii) shall not include 
                        Saturdays, Sundays, and legal public holidays.
                    ``(C) Failure to meet time limits.--
                            ``(i) In general.--Any person making a 
                        request for the disclosure of return or return 
                        information which is subject to this paragraph 
                        shall be deemed to have exhausted his 
                        administrative remedies with respect to such 
                        request if the Secretary fails to comply with 
                        the applicable time limit provisions of this 
                        paragraph. If the Secretary can show 
                        exceptional circumstances exist and that the 
                        agency is exercising due diligence in 
                        responding to the request, the court may retain 
                        jurisdiction and allow the agency additional 
                        time to complete its review of the records. 
                        Upon any determination by the Secretary to 
                        comply with a request for records, the records 
                        shall be made promptly available to such person 
                        making such request. Any notification of denial 
                        of any request for records under this 
                        subsection shall set forth the names and titles 
                        or positions of each person responsible for the 
                        denial of such request.
                            ``(ii) Exceptional circumstances defined.--
                        For purposes of clause (i), the term 
                        `exceptional circumstances' does not include a 
                        delay that results from a predictable workload 
                        of the Secretary relating to requests subject 
                        to this paragraph, unless the Secretary 
                        demonstrates reasonable progress in reducing 
                        its backlog of pending requests.
                            ``(iii) Refusal to modify request or time 
                        frame.--Refusal by a person to reasonably 
                        modify the scope of a request or arrange an 
                        alternative time frame for processing a request 
                        (or a modified request) under subparagraph 
                        (B)(ii) after being given an opportunity to do 
                        so by the agency to whom the person made the 
                        request shall be considered as a factor in 
                        determining whether exceptional circumstances 
                        exist for purposes of this subparagraph.
                    ``(D) Judicial proceedings.--
                            ``(i) Jurisdiction of the district 
                        courts.--
                                    ``(I) In general.--On complaint, 
                                the district courts of the United 
                                States in the district in which the 
                                complainant resides, or has his 
                                principal place of business, or in 
                                which his return or return information 
                                is situated, or in the District of 
                                Columbia, shall have jurisdiction to 
                                enjoin the Secretary from withholding 
                                return or return information which is 
                                subject to disclosure under subsection 
                                (c), (e), or (k)(1) or (2), and to 
                                order the production of any return or 
                                return information improperly withheld 
                                from the complainant.
                                    ``(II) Expedited processing.--No 
                                district court of the United States 
                                shall have jurisdiction to review a 
                                denial by the Secretary of expedited 
                                processing of a request for return or 
                                return information after the Secretary 
                                has provided a complete response to the 
                                request.
                            ``(ii) Procedural matters.--In a case 
                        arising under clause (i), the court shall 
                        determine the matter de novo (on the record 
                        before the Secretary at the time of the 
                        determination in the case of a request for 
                        expedited processing), and may examine the 
                        contents of such return or return information 
                        in camera to determine whether such return or 
                        return information or any part thereof shall be 
                        withheld under any of the provisions of this 
                        title, and the burden shall be on the Secretary 
                        to sustain its action. In addition to any other 
                        matters to which a court accords substantial 
                        weight, a court shall accord substantial weight 
                        to an affidavit of the Secretary concerning the 
                        Secretary's determination as to technical 
                        feasibility relating to, and reproducibility 
                        of, such return and return information.
                    ``(E) Deadline for Secretary to answer complaint.--
                Notwithstanding any other provision of law, the 
                Secretary shall serve an answer or otherwise plead to 
                any complaint made under this paragraph within 30 days 
                after service upon the Secretary of the pleading in 
                which such complaint is made, unless the court 
                otherwise directs for good cause shown.''.
    (c) Attorney Fees.--Subsection (a) of section 7430 (relating to 
general rule for awarding of costs and certain fees) is amended by 
inserting after ``title,'' the following: ``and in any court proceeding 
in connection with the disclosure of return and return information 
under section 6103(p)(9),''.
    (d) Effective Date.--The amendments made by this section shall 
apply to requests made after the date of the enactment of this Act.

SEC. 202. EXPANSION OF TYPE OF ADVICE AVAILABLE FOR PUBLIC INSPECTION.

    (a) In General.--Subparagraph (A) of section 6110(i)(1) is 
amended--
            (1) by striking ``national office component of the Office 
        of Chief Counsel'' and inserting ``component of the Office of 
        Chief Counsel or of the Service''; and
            (2) in clause (i) by striking ``field or service center 
        employees of the Service or regional or district'' and 
        inserting ``employees of the Service or''.
    (b) Conforming Amendments.--
            (1) Section 6110(i)(2) is amended by inserting ``or the 
        Service'' after ``Office of Chief Counsel''.
            (2) The following provisions of section 6110 are amended by 
        striking ``Chief Counsel advice'' each place it appears and 
        inserting ``official advice'':
                    (A) Paragraph (1) of subsection (b).
                    (B) Subparagraph (A) of subsection (i)(1).
                    (C) Paragraphs (3) and (4) of subsection (i).
            (3) Subparagraph (A) of section 6110(g)(5) is amended by 
        inserting ``official advice and'' before ``technical advice''.
            (4) The heading for subsection (i) of section 6110 is 
        amended by striking ``Chief Counsel'' and inserting 
        ``Official''.
            (5) The heading for paragraph (1) of section 6110(i) is 
        amended by striking ``Chief counsel'' and inserting 
        ``Official''.
            (6) The headings for paragraphs (2) and (3) of section 
        6110(i), and for subparagraphs (A) and (B) of paragraph (4) of 
        such section, are each amended by striking ``chief counsel'' 
        and inserting ``official''.
    (c) Effective Date.--
            (1) In general.--The amendments made by this section shall 
        apply to any official advice issued more than 90 days after the 
        date of the enactment of this Act.
            (2) Documents treated as official advice.--If the Secretary 
        of the Treasury by regulation provides pursuant to section 
        6110(i)(2) of the Internal Revenue Code of 1986, that any 
        additional advice or instruction issued by the Office of Chief 
        Counsel shall be treated as official advice, such additional 
        advice or instruction shall be made available for public 
        inspection pursuant to section 6110 of such Code, as amended by 
        this section, only in accordance with the effective date set 
        forth in such regulation.
            (3) Official advice to be available electronically.--The 
        Internal Revenue Service shall make any official advice issued 
        more than 90 days after the date of the enactment of this Act 
        and made available for public inspection pursuant to section 
        6110 of the Internal Revenue Code of 1986, as amended by this 
        section, also available by computer telecommunications within 1 
        year after issuance.

SEC. 203. COLLECTION ACTIVITIES WITH RESPECT TO JOINT RETURN 
              DISCLOSABLE TO EITHER SPOUSE BASED ON ORAL REQUEST.

    (a) In General.--Paragraph (8) of section 6103(e) (relating to 
disclosure of collection activities with respect to joint return) is 
amended by striking ``in writing'' the first place it appears.
    (b) Effective Date.--The amendment made by this section shall apply 
to requests made after the date of the enactment of this Act.

SEC. 204. TAXPAYER REPRESENTATIVES NOT SUBJECT TO EXAMINATION ON SOLE 
              BASIS OF REPRESENTATION OF TAXPAYERS.

    (a) In General.--Subsection (h) of section 6103 (relating to 
disclosure to certain Federal officers and employees for purposes of 
tax administration, etc.) is amended by adding at the end the following 
new paragraph:
            ``(7) Taxpayer representatives.--Notwithstanding paragraph 
        (1), the return of the representative of a taxpayer whose 
        return is being examined by an officer or employee of the 
        Department of the Treasury shall not be open to inspection by 
        such officer or employee on the sole basis of the 
        representative's relationship to the taxpayer unless a 
        supervisor of such officer or employee has approved the 
        inspection of the return of such representative on a basis 
        other than by reason of such relationship.''.
    (b) Effective Date.--The amendment made by this section shall take 
effect on the date of the enactment of this Act.

SEC. 205. DISCLOSURE IN JUDICIAL OR ADMINISTRATIVE TAX PROCEEDINGS OF 
              RETURN AND RETURN INFORMATION OF PERSONS WHO ARE NOT 
              PARTY TO SUCH PROCEEDINGS.

    (a) In General.--Paragraph (4) of section 6103(h) (relating to 
disclosure to certain Federal officers and employees for purposes of 
tax administration, etc.) is amended by adding at the end the following 
new subparagraph:
                    ``(B) Disclosure in judicial or administrative tax 
                proceedings of return and return information of persons 
                not party to such proceedings.--
                            ``(i) Notice.--Return or return information 
                        of any person who is not a party to a judicial 
                        or administrative proceeding described in 
                        paragraph (4) shall not be disclosed under 
                        clause (ii) or (iii) of subparagraph (A) until 
                        after the Secretary makes a reasonable effort 
                        to give notice to such person and an 
                        opportunity for such person to request the 
                        deletion of matter from such return or return 
                        information, including any of the items 
                        referred to in paragraphs (1) through (7) of 
                        section 6110(c). Such notice shall include a 
                        statement of the issue or issues the resolution 
                        of which is the reason such return or return 
                        information is sought. In the case of S 
                        corporations, partnerships, estates, and 
                        trusts, such notice shall be made at the entity 
                        level.
                            ``(ii) Disclosure limited to pertinent 
                        portion.--The only portion of a return or 
                        return information described in clause (i) 
                        which may be disclosed under subparagraph (A) 
                        is that portion of such return or return 
                        information that directly relates to the 
                        resolution of an issue in such proceeding.
                            ``(iii) Exceptions.--Clause (i) shall not 
                        apply to--
                                    ``(I) any ex parte proceeding for 
                                obtaining a search warrant, order for 
                                entry on premises or safe deposit 
                                boxes, or similar ex parte proceeding,
                                    ``(II) disclosure of third party 
                                return information by indictment or 
                                criminal information, or
                                    ``(III) if the Secretary determines 
                                that the application of such clause 
                                would seriously impair a criminal tax 
                                investigation.''.
    (b) Conforming Amendments.--Paragraph (4) of section 6103(h) is 
amended by--
            (1) by striking ``proceedings.--A return'' and inserting 
        ``proceedings.--
                    ``(A) In general.--Except as provided in 
                subparagraph (B), a return'';
            (2) by redesignating subparagraphs (A), (B), (C), and (D) 
        clauses (i), (ii), (iii), and (iv), respectively; and
            (3) in the matter following clause (iv) (as so 
        redesignated), by striking ``subparagraph (A), (B), or (C)'' 
        and inserting ``clause (i), (ii), or (iii)'' and by moving such 
        matter 2 ems to the right.
    (c) Effective Date.--The amendments made by this section shall 
apply to proceedings commenced after the date of the enactment of this 
Act.

SEC. 206. PROHIBITION OF DISCLOSURE OF TAXPAYER IDENTIFICATION 
              INFORMATION WITH RESPECT TO DISCLOSURE OF ACCEPTED 
              OFFERS-IN-COMPROMISE.

    (a) In General.--Paragraph (1) of section 6103(k) (relating to 
disclosure of certain returns and return information for tax 
administrative purposes) is amended by inserting ``(other than address 
and TIN)'' after ``Return information''.
    (b) Effective Date.--The amendment made by this section shall apply 
to disclosures made after the date of the enactment of this Act.

SEC. 207. COMPLIANCE BY STATE CONTRACTORS WITH CONFIDENTIALITY 
              SAFEGUARDS.

    (a) In General.--Paragraph (8) of section 6103(p) (relating to 
State law requirements) is amended by redesignating subparagraph (B) as 
subparagraph (C) and by inserting after subparagraph (A) the following 
new subparagraph:
                    ``(B) Disclosure to contractors.--Notwithstanding 
                any other provision of this section, no return or 
                return information shall be disclosed by any officer or 
                employee of any State to any contractor of the State 
                unless such State--
                            ``(i) has requirements in effect which 
                        require each contractor of the State which 
                        would have access to returns or return 
                        information to provide safeguards (within the 
                        meaning of paragraph (4)) to protect the 
                        confidentiality of such returns or return 
                        information,
                            ``(ii) agrees to conduct an annual, on-site 
                        review (mid-point review in the case of 
                        contracts of less than 1 year in duration) of 
                        each contractor to determine compliance with 
                        such requirements,
                            ``(iii) submits the findings of the most 
                        recent review conducted under clause (ii) to 
                        the Secretary as part of the report required by 
                        paragraph (4)(E), and
                            ``(iv) certifies to the Secretary for the 
                        most recent annual period that all contractors 
                        are in compliance with all such requirements.
                The certification required by clause (iv) shall include 
                the name and address of each contractor, a description 
                of the contract of the contractor with the State, and 
                the duration of such contract.''.
    (b) Conforming Amendment.--Subparagraph (C) of section 6103(p)(8), 
as amended by subsection (a), is amended by striking ``subparagraph 
(A)'' and inserting ``subparagraphs (A) and (B)''.
    (c) Effective Date.--
            (1) In general.--The amendments made by this section shall 
        apply to disclosures made after December 31, 2001.
            (2) The first certification under section 6103(p)(8)(B)(iv) 
        of the Internal Revenue Code of 1986, as added by subsection 
        (a), shall be made with respect to calendar year 2002.

SEC. 208. HIGHER STANDARDS FOR REQUESTS FOR AND CONSENTS TO DISCLOSURE.

    (a) In General.--Subsection (c) of section 6103 (relating to 
disclosure of returns and return information to designee of taxpayer) 
is amended by adding at the end the following new paragraphs:
            ``(2) Requirements for valid requests and consents.--A 
        request for or consent to disclosure under paragraph (1) shall 
        only be valid for purposes of this section or sections 7213, 
        7213A, or 7431 if--
                    ``(A) at the time of execution, such request or 
                consent designates a recipient of such disclosure and 
                is dated, and
                    ``(B) at the time such request or consent is 
                submitted to the Secretary, the submitter of such 
                request or consent certifies, under penalty of perjury, 
                that such request or consent complied with subparagraph 
                (A).
            ``(3) Restrictions on persons obtaining information.--Any 
        person shall, as a condition for receiving return or return 
        information under paragraph (1)--
                    ``(A) ensure that such return and return 
                information is kept confidential,
                    ``(B) use such return and return information only 
                for the purpose for which it was requested, and
                    ``(C) not disclose such return and return 
                information except to accomplish the purpose for which 
                it was requested, unless a separate consent from the 
                taxpayer is obtained.
            ``(4) Requirements for form prescribed by secretary.--For 
        purposes of this subsection, the Secretary shall prescribe a 
        form for requests and consents which shall--
                    ``(A) contain a warning, prominently displayed, 
                informing the taxpayer that the form should not be 
                signed unless it is completed,
                    ``(B) state that if the taxpayer believes there is 
                an attempt to coerce him to sign an incomplete or blank 
                form, the taxpayer should report the matter to the 
                Treasury Inspector General for Tax Administration, and
                    ``(C) contain the address and telephone number of 
                the Treasury Inspector General for Tax 
                Administration.''.
    (b) Report.--Not later than 18 months after the date of the 
enactment of this Act, the Treasury Inspector General for Tax 
Administration shall submit a report to the Congress on compliance with 
the designation and certification requirements applicable to requests 
for or consent to disclosure of returns and return information under 
section 6103(c) of the Internal Revenue Code of 1986, as amended by 
subsection (a). Such report shall--
            (1) evaluate (on the basis of random sampling) whether--
                    (A) the amendments made by subsection (a) are 
                achieving the purposes of this section;
                    (B) requesters and submitters for such disclosure 
                are continuing to evade the purposes of this section 
                and, if so, how; and
                    (C) the sanctions for violations of such 
                requirements are adequate; and
            (2) include such recommendations that the Treasury 
        Inspector General for Tax Administration considers necessary or 
        appropriate to better achieve the purposes of this section.
    (c) Conforming Amendment.--Section 6103(c) is amended by striking 
``Taxpayer.--The Secretary'' and inserting ``Taxpayer.--
            ``(1) In General.--The Secretary''.
    (d) Effective Date.--The amendments made by this section shall 
apply to requests and consents made after 3 months after the date of 
the enactment of this Act.

SEC. 209. NOTICE TO TAXPAYER CONCERNING ADMINISTRATIVE DETERMINATION OF 
              BROWSING; ANNUAL REPORT.

    (a) Notice to Taxpayer.--Subsection (e) of section 7431 (relating 
to notification of unlawful inspection and disclosure) is amended by 
adding at the end the following: ``The Secretary shall also notify such 
taxpayer if the Treasury Inspector General for Tax Administration 
determines that such taxpayer's return or return information was 
inspected or disclosed in violation of any of the provisions specified 
in paragraph (1), (2), or (3).''.
    (b) Reports.--Subsection (p) of section 6103 (relating to procedure 
and recordkeeping), as amended by section 201(b), is further amended by 
adding at the end the following new paragraph:
            ``(10) Report on unauthorized disclosure and inspection.--
        As part of the report required by paragraph (3)(C) for each 
        calendar year, the Secretary shall furnish information 
        regarding the unauthorized disclosure and inspection of returns 
        and return information, including the number, status, and 
        results of--
                    ``(A) administrative investigations,
                    ``(B) civil lawsuits brought under section 7431 
                (including the amounts for which such lawsuits were 
                settled and the amounts of damages awarded), and
                    ``(C) criminal prosecutions.''.
    (c) Effective Date.--
            (1) Notice.--The amendment made by subsection (a) shall 
        apply to determinations made after the date of the enactment of 
        this Act.
            (2) Reports.--The amendment made by subsection (b) shall 
        apply to calendar years ending after the date of the enactment 
        of this Act.

SEC. 210. DISCLOSURE OF TAXPAYER IDENTITY FOR TAX REFUND PURPOSES.

    Paragraph (1) of section 6103(m) (relating to disclosure of 
taxpayer identity information for tax refunds) is amended by inserting 
``, and through any other means of mass communication,'' after 
``media''.

                     TITLE III--OTHER REQUIREMENTS

SEC. 301. CLARIFICATION OF DEFINITION OF CHURCH TAX INQUIRY.

    Subsection (i) of section 7611 (relating to section not to apply to 
criminal investigations, etc.) is amended by striking ``or'' at the end 
of paragraph (4), by striking the period at the end of paragraph (5) 
and inserting ``, or'', and by inserting after paragraph (5) the 
following:
            ``(6) information provided by the Secretary related to the 
        standards for exemption from tax under this title and the 
        requirements under this title relating to unrelated business 
        taxable income.''.

SEC. 302. EXPANSION OF DECLARATORY JUDGMENT REMEDY TO TAX-EXEMPT 
              ORGANIZATIONS.

    (a) In General.--Paragraph (1) of section 7428(a) (relating to 
creation of remedy) is amended--
            (1) in subparagraph (B) by inserting after ``509(a))'' the 
        following: ``or as a private operating foundation (as defined 
        in section 4942(j)(3))''; and
            (2) by amending subparagraph (C) to read as follows:
                    ``(C) with respect to the initial qualification or 
                continuing qualification of an organization as an 
                organization described in section 501(c) (other than 
                paragraph (3)) which is exempt from tax under section 
                501(a), or''.
    (b) Court Jurisdiction.--Subsection (a) of section 7428 is amended 
in the material following paragraph (2) by striking ``United States Tax 
Court, the United States Claims Court, or the district court of the 
United States for the District of Columbia'' and inserting the 
following: ``United States Tax Court (in the case of any such 
determination or failure) or the United States Claims Court or the 
district court of the United States for the District of Columbia (in 
the case of a determination or failure with respect to an issue 
referred to in subparagraph (A) or (B) of paragraph (1)),''.
    (c) Failure of Service To Act on Determinations Treated as 
Exhaustion of Remedies.--The second sentence of paragraph (2) of 
section 7428(b) (relating to exhaustion of administrative remedies) is 
amended to read as follows: ``An organization requesting the 
determination of an issue referred to in subsection (a)(1) shall be 
deemed to have exhausted its administrative remedies with respect to--
                    ``(A) a failure by the Secretary to make a 
                determination with respect to such issue at the 
                expiration of 270 days after the date on which the 
                request for such determination was made if the 
                organization has taken, in a timely manner, all 
                reasonable steps to secure such determination, and
                    ``(B) a failure by any office of the Service (other 
                than the office which is responsible for initial 
                determinations with respect to such issue (hereinafter 
                in this subparagraph referred to as the `initial 
                office'), to make a determination with respect to such 
                issue at the expiration of 180 days after the date on 
                which any request for such determination was made by 
                the initial office if the organization has taken, in a 
                timely manner, all reasonable steps to secure such 
                determination.''.
    (d) Effective Dates.--
            (1) Declaratory judgment.--The amendments made by 
        subsections (a) and (b) shall apply to pleadings filed with 
        respect to determinations (or requests for determinations) made 
        after the date of the enactment of this Act.
            (2) Failure of service to act.--The amendments made by 
        subsection (c) shall apply to applications received in the 
        national office of the Internal Revenue Service after the date 
        of the enactment of this Act.

SEC. 303. EMPLOYEE MISCONDUCT REPORT TO INCLUDE SUMMARY OF COMPLAINTS 
              BY CATEGORY.

    (a) In General.--Clause (ii) of section 7803(d)(2)(A) is amended by 
inserting before the semicolon at the end the following: ``, including 
a summary (by category) of the 10 most common complaints made and the 
number of such common complaints''.
    (b) Effective Date.--The amendment made by subsection (a) shall 
apply with respect to reporting periods ending after the date of the 
enactment of this Act.

SEC. 304. INCREASE IN THRESHOLD FOR JOINT COMMITTEE REPORTS ON REFUNDS 
              AND CREDITS.

    (a) General Rule.--Subsections (a) and (b) of section 6405 are each 
amended by striking ``$1,000,000'' and inserting ``$2,000,000''.
    (b) Effective Date.--The amendment made by subsection (a) shall 
take effect on the date of the enactment of this Act, except that such 
amendment shall not apply with respect to any refund or credit with 
respect to a report that has been made before such date of the 
enactment under section 6405 of the Internal Revenue Code of 1986.

SEC. 305. ANNUAL REPORT ON AWARDS OF COSTS AND CERTAIN FEES IN 
              ADMINISTRATIVE AND COURT PROCEEDINGS.

    Not later than 3 months after the close of each Federal fiscal year 
after fiscal year 1999, the Treasury Inspector General for Tax 
Administration shall submit a report to Congress which specifies for 
such year--
            (1) the number of payments made by the United States 
        pursuant to section 7430 of the Internal Revenue Code of 1986 
        (relating to awarding of costs and certain fees);
            (2) the amount of each such payment;
            (3) an analysis of any administrative issue giving rise to 
        such payments; and
            (4) changes (if any) which will be implemented as a result 
        of such analysis and other changes (if any) recommended by the 
        Treasury Inspector General for Tax Administration as a result 
        of such analysis.

SEC. 306. ANNUAL REPORT ON ABATEMENT OF PENALTIES.

    Not later than 6 months after the close of each Federal fiscal year 
after fiscal year 1999, the Treasury Inspector General for Tax 
Administration shall submit a report to Congress on abatements of 
penalties under the Internal Revenue Code of 1986 during such year, 
including information on the reasons and criteria for such abatements.

SEC. 307. BETTER MEANS OF COMMUNICATING WITH TAXPAYERS.

    Not later than 18 months after the date of the enactment of this 
Act, the Treasury Inspector General for Tax Administration shall submit 
a report to Congress evaluating whether technological advances, such as 
e-mail and facsimile transmission, permit the use of alternative means 
for the Internal Revenue Service to communicate with taxpayers.

SEC. 308. EXPLANATION OF STATUTE OF LIMITATIONS AND CONSEQUENCES OF 
              FAILURE TO FILE.

    The Secretary of the Treasury or the Secretary's delegate shall, as 
soon as practicable but not later than 180 days after the date of the 
enactment of this Act, revise the statement required by section 6227 of 
the Omnibus Taxpayer Bill of Rights (Internal Revenue Service 
Publication No. 1), and any instructions booklet accompanying a general 
income tax return form for taxable years beginning in 2000 and later 
(including forms 1040, 1040A, 1040EZ, and any similar or successor 
forms relating thereto), to provide for an explanation of--
            (1) the limitations imposed by section 6511 of the Internal 
        Revenue Code of 1986 on credits and refunds; and
            (2) the consequences under such section 6511 of the failure 
        to file a return of tax.

            Passed the House of Representatives April 11, 2000.

            Attest:

                                                                 Clerk.