[Congressional Record Volume 144, Number 56 (Thursday, May 7, 1998)]
[Senate]
[Pages S4543-S4547]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]




                          AMENDMENTS SUBMITTED

                                 ______
                                 

   THE INTERNAL REVENUE SERVICE RESTRUCTURING AND REFORM ACT OF 1998

                                 ______
                                 

                    KERREY AMENDMENTS NOS. 2358-2359

  Mr. KERREY proposed two amendments to the bill (H.R. 2676) to amend 
the Internal Revenue Code of 1986 to restructure and reform the 
Internal Revenue Service, and for other purposes; as follows:

                           Amendment No. 2358

       On page 394, between lines 15 and 16, insert the following:

     SEC. --. WILLFUL NONCOMPLIANCE WITH INTERNAL REVENUE LAWS BY 
                   TAXPAYERS.

       Not later than 1 year after the date of enactment of this 
     Act, the Joint Committee on Taxation, the Secretary of the 
     Treasury, and the Commissioner of Internal Revenue shall 
     conduct jointly a study of the willful noncompliance with 
     internal revenue laws by taxpayers and report the findings of 
     such study to Congress.
                                  ____


                           Amendment No. 2359

       On page 368, strike line 1 and insert the following:
       (c) Annual Report.--The Inspector General for Tax 
     Administration shall report annually to Congress on any 
     administrative or civil actions with respect to violations of 
     the fair debt collection provisions of section 6304 of the 
     Internal Revenue Code of 1986, as added by this section, 
     including--
       (1) a summary of such actions initiated since the date of 
     the last report, and
       (2) a summary of any judgments or awards granted as a 
     result of such actions.
       (d) Effective Date.--The amendments made by this
                                 ______
                                 

                FAIRCLOTH (AND SMITH) AMENDMENT NO. 2360

  Mr. FAIRCLOTH (for himself and Mr. Smith of New Hampshire) proposed 
an amendment to the bill, H.R. 2676, supra; as follows:

       On page 174, line 23, strike ``9'' and insert ``8''.
       On page 175, strike lines 8 through 13.
       On page 176, line 10, strike ``or (D)''.
       On page 177, strike lines 7 and 8, and insert the 
     following:
       ``(A) Financial disclosure.--During the entire
       On page 177, line 10, strike ``or (D)''.
       Beginning on page 177, strike line 19 and all that follows 
     through page 178, line 5.
       On page 178, line 10, strike ``or (D)''.
       On page 182, line 1, strike ``or (D)''.
       On page 182, line 11, strike ``or (D)''.
       On page 190, line 12, strike ``or (D)''.
                                 ______
                                 

                       KERREY AMENDMENT NO. 2361

  Mr. KERREY proposed an amendment to the bill, H.R. 2676, supra; as 
follows:

       On page 256, line 15, strike ``and''.
       On page 256, line 18, strike ``2007.'' and insert ``2007, 
     and''.
       On page 256, between lines 18 and 19, insert the following:
       (3) the Internal Revenue Service should cooperate with the 
     private sector by encouraging competition to increase 
     electronic filing of such returns, consistent with the 
     provisions of the Office of Management and Budget Circular A-
     76.
                                 ______
                                 

                   GRASSLEY AMENDMENTS NOS. 2362-2363

  Mr. GRASSLEY proposed two amendments to the bill, H.R. 2676, supra; 
as follows:

                           Amendment No. 2362

       On page 203, line 5, strike ``and''.
       On page 203, line 10, strike the period and insert ``, 
     and''.
       On page 203, between lines 10 and 11, insert:
       ``(III) appoint a counsel in the Office of the Taxpayer 
     Advocate to report directly to the National Taxpayer 
     Advocate.
                                  ____


                           Amendment No. 2363

       At the end of subtitle H of title III, insert the 
     following:

     SEC. ----. COMBINED EMPLOYMENT TAX REPORTING DEMONSTRATION 
                   PROJECT.

       (a) In General.--The Secretary of the Treasury shall 
     provide for a demonstration project to assess the feasibility 
     and desirability of expanding combined Federal and State tax 
     reporting.
       (b) Description of Demonstration Project.--The 
     demonstration project under subsection (a) shall be--
       (1) carried out between the Internal Revenue Service and 
     the State of Iowa for a period ending with the date which is 
     5 years after the date of the enactment of this Act,
       (2) limited to the reporting of employment taxes, and
       (3) limited to the disclosure of the taxpayer identity (as 
     defined in section 6103(b)(6) of such Code) and the signature 
     of the taxpayer.
       (c) Conforming Amendment.--Section 6103(d)(5), as amended 
     by section 6009(f), is amended by striking ``project 
     described in section 976 of the Taxpayer Relief Act of 
     1997.'' and inserting ``projects described in section 976 of 
     the Taxpayer Relief Act of 1997 and section ________ of the 
     Internal Revenue Service Restructuring and Reform Act of 
     1998.''.
                                 ______
                                 

                    CRAIG AMENDMENTS NOS. 2364-2366

  Mr. CRAIG proposed three amendments to the bill, H.R. 2676, supra; as 
follows:

                           Amendment No. 2364

       Insert in the appropriate place in the bill the following:

     SEC.   . TAXPAYER NOTICE.

       Section 6103(d) of the Internal Revenue Code of 1986 is 
     amended by adding at the end thereof a new paragraph to read 
     as follows:
       ``(6) Taxpayer notice.--No return information may be 
     disclosed under paragraph (1) to any agency, body, or 
     commission of any State (or legal representative thereof) 
     unless the Secretary determines that such agency, body, or 
     commission (or legal representative) has first notified each 
     person for whom such return or return information was filed 
     or provided by, on behalf of, or with respect to, personally 
     in writing that the request described in paragraph (1) has 
     been made by such agency, body, or commission (or legal 
     representative) and the specific reasons for making such 
     request.''.
                                  ____


                           Amendment No. 2365

       Insert in the appropriate places in the bill the following:

     SEC.   . DISCLOSURE NECESSARY IN THE ADMINISTRATION OF STATE 
                   INCOME TAX LAWS.

       (a) Section 6103(b)(5)(A) of the Internal Revenue Code of 
     1986 is amended by inserting after ``Northern Mariana 
     Islands,'' the following:

     ``if that jurisdiction imposes a tax on income or wages,''.
       (b) The first sentence of Section 6103(d)(1) is amended by 
     inserting the word ``income'' after ``with responsibility for 
     the administration of State'' and before ``tax laws''.
       The first sentence of Section 6103(d)(1) is further amended 
     by inserting ``State's income tax'' after ``necessary in, the 
     administration of such'', and before ``laws''.
                                  ____


                           Amendment No. 2366

       Insert in the appropriate place in the bill the following:

     SEC.   . DISCLOSURE TO TAXPAYERS.

       Section 6103(d) of the Internal Revenue Code of 1986 is 
     amended by adding at the end thereof a new paragraph to read 
     as follows:
       ``(6) Disclosure to taxpayers.--The Secretary shall ensure 
     that any instructions booklet accompanying a general tax 
     return form (including forms 1040, 1040A, 1040EZ, and any 
     similar or successor forms) shall include, in clear language, 
     in conspicuous print, and in a conspicuous place near the 
     front of the booklet, a complete and concise description of 
     the conditions under which return information may be 
     disclosed to any party outside the Internal Revenue Service, 
     including disclosure to any State or agency, body, or 
     commission (or legal representative) thereof.''.
                                 ______
                                 

                        BOND AMENDMENT NO. 2367

  (Ordered to lie on the table.)
  Mr. BOND submitted an amendment intended to be proposed by him to the 
bill, H.R. 2676, supra; as follows:


[[Page S4544]]


       Beginning on page 256, strike line 9 and all that follows 
     through page 258, line 21, and insert the following:

     SEC. 2001. ELECTRONIC FILING OF TAX AND INFORMATION RETURNS.

       (a) In General.--It is the policy of Congress that--
       (1) paperless filing should be the preferred and most 
     convenient means of filing Federal tax and information 
     returns,
       (2) electronic filing should be a voluntary option for 
     taxpayers, and
       (3) it be the goal of the Internal Revenue Service to have 
     at least 80 percent of all such returns filed electronically 
     by the year 2007.
       (b) Strategic Plan.--
       (1) In general.--Not later than 180 days after the date of 
     enactment of this Act, the Secretary of the Treasury or the 
     Secretary's delegate (hereafter in this section referred to 
     as the ``Secretary''), in consultation with the Internal 
     Revenue Service Oversight Board and the electronic-filing 
     advisory group described in paragraph (4), shall establish a 
     plan to eliminate barriers, provide incentives, and use 
     competitive market forces to increase electronic filing 
     gradually over the next 10 years while maintaining processing 
     times for paper returns at 40 days.
       (2) Publication of plan.--The plan described in paragraph 
     (1) shall be published in the Federal Register and shall be 
     subject to public comment for 60 days from the date of 
     publication. Not later than 180 days after publication of 
     such plan, the Secretary shall publish a final plan in the 
     Federal Register.
       (3) Implementation of plan.--The Secretary shall prescribe 
     rules and regulations to implement the plan developed under 
     paragraph (1). Notwithstanding any other provision of law, 
     the Secretary shall--
       (A) prescribe such rules and regulations in accordance with 
     subsections (b), (c), (d), and (e) of section 553 of title 5, 
     United States Code, and
       (B) in connection with such rules and regulations, perform 
     an initial and final regulatory flexibility analysis pursuant 
     to sections 603 and 604 of title 5, United States Code, and 
     outreach pursuant to section 609 of title 5, United States 
     Code.
       (4) Electronic-filing advisory group.--
       (A) In general.--To ensure that the Secretary receives 
     input from the private sector in the development and 
     implementation of the plan required by paragraph (1), not 
     later than 60 days after the date of enactment of this Act, 
     the Secretary shall convene an electronic-filing advisory 
     group that includes--
       (i) at least one representative of individual taxpayers 
     subject to withholding,
       (ii) small businesses and self-employed individuals,
       (iii) large businesses,
       (iv) trusts and estates,
       (v) tax-exempt organizations,
       (vi) tax practitioners, preparers, and other tax 
     professionals,
       (vii) computerized tax processors, and
       (viii) the electronic-filing industry.
       (B) Personnel and other matters.--
       (i) Compensation.--Each member of the electronic-filing 
     advisory group described in subparagraph (A) shall serve 
     without compensation, but shall be allowed travel expenses, 
     including per diem in lieu of subsistence, at rates 
     authorized for employees of agencies under subchapter I of 
     chapter 57 of title 5, United States Code, while away from 
     their homes or regular places of business in performance of 
     duties as members of the advisory group.
       (ii) Detailees.--Any Federal Government employee may be 
     detailed to the advisory group without reimbursement, and 
     such detail shall be without interruption or loss of civil 
     service status or privilege.
       (5) Termination.--The advisory group shall terminate on 
     December 31, 2008.
       (c) Promotion of Electronic Filing and Incentives.--Section 
     6011 is amended by redesignating subsection (f) as subsection 
     (g) and by inserting after subsection (e) the following new 
     subsection:
       ``(f) Promotion of Electronic Filing.--
       ``(1) In general.--The Secretary is authorized to promote 
     the benefits of and encourage the use of electronic tax 
     administration programs, as they become available, through 
     the use of mass communications and other means.
       ``(2) Incentives.--The Secretary may implement procedures 
     to provide for the payment of appropriate incentives for 
     electronically filed returns.''
       (d) Annual Reports.--Not later than June 30 of each 
     calendar year after 1997 and before 2009, the Chairperson of 
     the Internal Revenue Service Oversight Board, the Secretary 
     of the Treasury, and the Chairperson of the electronic-filing 
     advisory group established under subsection (b)(4) shall 
     report to the Committees on Ways and Means, Appropriations, 
     Government Reform and Oversight, and Small Business of the 
     House of Representatives, the Committees on Finance, 
     Appropriations, Governmental Affairs, and Small Business of 
     the Senate, and the Joint Committee on Taxation, on--
       (1) the progress of the Internal Revenue Service in meeting 
     the goal of receiving 80 percent of tax and information 
     returns electronically by 2007,
       (2) the status of the plan required by subsection (b),
       (3) the legislative changes necessary to assist the 
     Internal Revenue Service in meeting such goal, and
       (4) the effects on small businesses and the self-employed 
     of electronically filing tax and information returns, 
     including a detailed description of the forms to be filed 
     electronically, the equipment and technology required for 
     compliance, the cost to a small business and self-employed 
     individual of filing electronically, implementation plans, 
     and action to coordinate Federal, State, and local electronic 
     filing requirements.
                                 ______
                                 

                GRASSLEY (AND OTHERS) AMENDMENT NO. 2368

  Mr. GRASSLEY (for himself, Mr. Kerrey, Mr. Hatch, Mr. Moynihan, Mr. 
Chafee, Mr. D'Amato, Mr. Jeffords, Mr. Rockefeller, Mr. Breaux, Mr. 
Conrad, Mr. Graham, Ms. Moseley-Braun, Mr. Bryan, Mrs. Boxer, Mr. 
Bennett, Mr. Dorgan, Mr. Akaka, and Mrs. Feinstein) proposed an 
amendment to the bill, H.R. 2676, supra; as follows:

       On page 386, lines 17 and 18, strike ``return for such 
     taxable year'' and insert ``Federal return for such taxable 
     year of the overpayment''.
       On page 387, line 23, insert ``by certified mail with 
     return receipt'' after ``notifies''.
       On page 388, strike lines 17 through 25, and insert the 
     following:
       ``(A)(i) which resulted from--
       ``(I) a judgment rendered by a court of competent 
     jurisdiction which has determined an amount of State income 
     tax to be due, or
       ``(II) a determination after an administrative hearing 
     which has determined an amount of State tax to be due, and
       ``(ii) which is no longer subject to judicial review, or
       ``(B) which resulted from a State income tax which has been 
     assessed but not collected, the time for redetermination of 
     which has expired, and which has not been delinquent for more 
     than 10 years.
                                 ______
                                 

                 GRAHAM (AND OTHERS) AMENDMENT NO. 2369

  Mr. GRAHAM (for himself, Mr. D'Amato, Mrs. Feinstein, and Mr. 
Johnson) proposed an amendment to the bill, H.R. 2676, supra; as 
follows:

       On page 293, strike lines 3 through 10, and insert:
       ``(C) Election not valid with respect to certain 
     deficiencies.--If the Secretary demonstrates that an 
     individual making an election under this section had actual 
     knowledge, at the time such individual signed the return, of 
     any item giving rise to a deficiency (or portion thereof) 
     which is not allocable to such individual under subsection 
     (c), such election shall not apply to such deficiency (or 
     portion). This subparagraph shall not apply where the 
     individual with actual knowledge establishes that such 
     individual signed the return under duress.
                                 ______
                                 

                DOMENICI (AND OTHERS) AMENDMENT NO. 2370

  Mr. ROTH (for Mr. Domenici, for himself, Mr. D'Amato, Mr. McCain, Mr. 
Bingaman, and Mrs. Hutchison) proposed an amendment to the bill, H.R. 
2676, supra; as follows:

       On page 381, after line 25, insert:
       (c) Telephone Helpline Options.--The Secretary of the 
     Treasury or the Secretary's delegate shall provide on all 
     telephone helplines of the Internal Revenue Service an option 
     for any taxpayer questions to be answered in Spanish.
       On page 382, strike lines 1 and 2, and insert:
       (e) Effective Dates.--
       (1) In general.--Except as otherwise provided in this 
     subsection, this section shall take effect 60 days after the 
     date of the enactment of this Act.
       (2) Subsection (c).--Subsection (c) shall take effect on 
     January 1, 2000.
                                 ______
                                 

                      DOMENICI AMENDMENT NO. 2371

  Mr. ROTH (for Mr. Domenici) proposed an amendment to the bill, H.R. 
2676, supra; as follows:

       On page 382, before line 1, insert:
       (d) Telephone Helpline Options.--The Secretary of the 
     Treasury or the Secretary's delegate shall provide on all 
     telephone helplines of the Internal Revenue Service an option 
     for any taxpayer to talk to a live person in addition to 
     hearing a recorded message. The person shall direct phone 
     questions of the taxpayer to other Internal Revenue Service 
     personnel who can provide understandable information to the 
     taxpayer.
       On page 382, after line 2, insert:
       (3) Subsection (d).--Subsection (d) shall take effect on 
     January 1, 2000.
                                 ______
                                 

                  MACK (AND OTHERS) AMENDMENT NO. 2372

  Mr. MACK (for himself, Mr. Faircloth, and Mr. Murkowski) proposed an 
amendment to the bill, H.R. 2676, supra; as follows:

       On page 174, line 23, strike ``9'' and insert ``8''.
       On page 175, strike lines 3 through 5.
       On page 175, line 6, strike ``(C)'' and insert ``(B)''.
       On page 175, line 8, strike ``(D)'' and insert ``(C)''.
       On page 176, line 10, strike ``(D)'' and insert ``(C)''.

[[Page S4545]]

       On page 177, line 10, strike ``(D)'' and insert ``(C)''.
       On page 177, line 21, strike ``(1)(D)'' and insert 
     ``(1)(C)''.
       On page 178, line 10, strike ``(D)'' and insert ``(C)''.
       On page 180, line 11, strike ``(1)(D)'' and insert 
     ``(1)(C)''.
       On page 180, line 18, strike ``(1)(D)'' and insert 
     ``(1)(C)''.
       On page 181, line 14, strike ``(1)(D)'' and insert 
     ``(1)(C)''.
       On page 182, strike lines 3 through 7, and insert the 
     following:
       ``(B) Commissioner.--The Commissioner of Internal Revenue 
     shall be removed upon termination of service in the office.
       On page 182, line 11, strike ``(D)'' and insert ``(C)''.
                                 ______
                                 

              BOND (AND MOSELEY-BRAUN) AMENDMENT NO. 2373

  Mr. BOND (for himself and Ms. Moseley-Braun) proposed an amendment to 
the bill, H.R. 2676, supra; as follows:

       Beginning on page 256, strike line 11 and all that follows 
     through line 18, and insert the following:
       ``(a) In General.--It is the policy of Congress that--
       (1) paperless filing should be the preferred and most 
     convenient means of filing Federal tax and information 
     returns,
       (2) electronic filing should be a voluntary option for 
     taxpayers, and
       (3) it should be the goal of the Internal Revenue Service 
     to have at least 80 percent of all such returns filed 
     electronically by the year 2007.''
       On page 258, line 12, strike ``and Government Reform and 
     Oversight'' insert ``Government Reform and Oversight, and 
     Small Business''.
       On page 258, line 14, strike ``and Governmental Affairs'' 
     insert ``Governmental Affairs, and Small Business''.
       On page 258, line 19, strike ``and''.
       On page 258, line 21, strike ``such goal.'' and insert 
     ``such goal; and''.
       On page 258, after line 21, insert the following:
       ``(4) the effects on small businesses and the self-employed 
     of electronically filing tax and information returns.''.
                                 ______
                                 

                    GRAMM AMENDMENTS NOS. 2374-2376

  Mr. GRAMM proposed three amendments to the bill, H.R. 2676, supra; as 
follows:

                           Amendment No. 2374

       On page 265, between lines 21 and 22, insert:
       ``(4) Expansion to tax liabilities other than income tax.--
     In the case of court proceedings arising in connection with 
     examinations commencing after the date of the enactment of 
     this paragraph and before June 1, 2001, this paragraph shall, 
     in addition to income tax liability, apply to any other tax 
     liability of the taxpayer.''
                                  ____


                           Amendment No. 2375

       On page 370, between lines 18 and 19, insert:

     SEC. 3468. PROHIBITION ON REQUESTS TO TAXPAYERS TO GIVE UP 
                   RIGHTS TO BRING ACTIONS.

       (a) Prohibition.--No officer or employee of the United 
     States may request a taxpayer to waive the taxpayer's right 
     to bring a civil action against the United States or any 
     officer or employee of the United States for any action taken 
     in connection with the internal revenue laws.
       (b) Exceptions.--Subsection (a) shall not apply in any case 
     where--
       (1) a taxpayer waives the right described in subsection (a) 
     knowingly and voluntarily, or
       (2) the request by the officer or employee is made in 
     person and the taxpayer's attorney or other federally 
     authorized tax practitioner (within the meaning of section 
     7525(c)(1)) is present, or the request is made in writing to 
     the taxpayer's attorney or other representative.
                                  ____


                           Amendment No. 2376

       On page 253, line 13, strike ``and''.
       On page 253, line 17, strike the end period and insert a 
     comma.
       On page 253, between lines 17 and 18, insert:
       (8) willful failure to file any return of tax required 
     under the Internal Revenue Code of 1986 on or before the date 
     prescribed therefor (including any extensions), unless such 
     failure is due to reasonable cause and not to willful 
     neglect,
       (9) willful understatement of Federal tax liability, unless 
     such understatement is due to reasonable cause and not to 
     willful neglect, and
       (10) threatening to audit a taxpayer for the purpose of 
     extracting personal gain or benefit.
                                 ______
                                 

                        CRAIG AMENDMENT NO. 2377

  Mr. ROTH (for Mr. Craig) proposed an amendment to the bill, H.R. 
2676, supra; as follows:

       Insert in the appropriate place in the bill the following:

     SEC.   . DISCLOSURE TO TAXPAYERS.

       Section 6103(d) of the Internal Revenue Code of 1986 is 
     amended by adding at the end thereof a new paragraph to read 
     as follows:
       ``(6) Disclosure to taxpayers.--The Secretary shall ensure 
     that any instructions booklet accompanying a general tax 
     return form (including forms 1040, 1040A, 1040EZ, and any 
     similar or successor forms) shall include, in clear language, 
     in conspicuous print, and in a conspicuous place near the 
     front of the booklet, a concise description of the conditions 
     under which return information may be disclosed to any party 
     outside the Internal Revenue Service, including disclosure to 
     any State or agency, body, or commission (or legal 
     representative) thereof.''.
                                 ______
                                 

                        CRAIG AMENDMENT NO. 2378

  Mr. ROTH (for Mr. Craig) proposed an amendment to the bill, H.R. 
2676, supra; as follows:

       On page 394, before line 16, add a new item (6) to read as 
     follows:
       ``(6) the impact on taxpayer privacy of the sharing of 
     income tax return information for purposes of enforcement of 
     state and local tax laws other than income tax laws, and 
     including the impact on the taxpayer privacy intended to be 
     protected at the federal, state, and local levels under 
     Public Law 105-35, the Taxpayer Browsing Protection Act of 
     1997.''
                                 ______
                                 

                 GRAMS (AND OTHERS) AMENDMENT NO. 2379

  Mr. GRAMS (for Mr. Coverdell, Ms. Boxer, Mr. Wellstone, and Mr. 
Cleland) proposed an amendment to the bill, H.R. 2676, supra; as 
follows:

       At the appropriate place, insert the following new section:

     SEC.   . ABATEMENT OF INTEREST ON UNDERPAYMENTS BY TAXPAYERS 
                   IN PRESIDENTIALLY DECLARED DISASTER AREAS.

       (a) In General.--Section 6404 of the Internal Revenue Code 
     of 1986 (relating to abatements) is amended by adding at the 
     end the following:
       ``(h) Abatement of Interest on Underpayments by Taxpayers 
     in Presidentially Declared Disaster Areas.--
       ``(1) In general.--If the Secretary extends for any period 
     the time for filing income tax returns under section 6081 and 
     the time for paying income tax with respect to such returns 
     under section 6161 for any taxpayer located in a 
     Presidentially declared disaster area, the Secretary shall 
     abate for such period the assessment of any interest 
     prescribed under section 6601 on such income tax.
       ``(2) Presidentially declared disaster area.--For purposes 
     of paragraph (1), the term `Presidentially declared disaster 
     area' means, with respect to any taxpayer, any area which the 
     President has determined warrants assistance by the Federal 
     Government under the Disaster Relief and Emergency Assistance 
     Act.''.
       (b) Effective Date.--The amendment made by this section 
     shall apply to disasters declared after December 31, 1996, 
     with respect to taxable years beginning after December 31, 
     1996.
       (c) Emergency Designation--
       (1) For the purposes of section 252(e) of the Balanced 
     Budget and Emergency Deficit Control Act, Congress designates 
     the provisions of this section as an emergency requirement.
       (2) The amendments made by subsections (a) and (b) of this 
     section shall only take effect upon the transmittal by the 
     President to the Congress of a message designating the 
     provisions of subsections (a) and (b) as an emergency 
     requirement pursuant to section 252(e) of the Balanced Budget 
     and Emergency Deficit Control Act.
                                 ______
                                 

                MOYNIHAN (AND OTHERS) AMENDMENT NO. 2380

  Mr. DODD (for Mr. Moynihan, for himself, Mr. Roth, Mr. Bennett, Mr. 
Kerrey, Mr. Dodd) proposed an amendment to the bill, H.R. 2676, supra; 
as follows:

       On page 308, line 12, insert ``the 2nd and succeeding'' 
     before ``calendar quarters''.
       On page 309, lines 7 and 8, strike ``the date of the 
     enactment of this Act'' and insert ``December 31, 1999''.
       On page 343, after line 24, insert:
       (c) Effective Date.--The amendments made by this section 
     shall take effect on the date of the enactment of this Act, 
     except for automated collection system actions initiated 
     before January 1, 2000.
       On page 345, lines 6 and 7, strike ``the date of the 
     enactment of this Act'' and insert ``December 31, 1999''.
       On page 351, lines 13 and 14, strike ``the date of the 
     enactment of this Act'' and insert ``December 31, 1999''.
       On page 357, lines 6 and 7, strike ``the date of the 
     enactment of this Act'' and insert ``December 31, 1999''.
       On page 357, lines 9 and 10, strike ``the date of the 
     enactment of this Act'' and insert ``December 31, 1999''.
       On page 357, strike lines 16 and 17, and insert:
       (B) December 31, 1999.
       On page 362, lines 12 and 13, strike ``the 60th day after 
     the date of the enactment of this Act'' and insert ``December 
     31, 1999''.
       On page 382, line 2, strike ``60 days after the date of the 
     enactment of this Act'' and insert ``on January 1, 2000''.

[[Page S4546]]

       On page 383, line 14, insert ``, except that the removal of 
     any designation under subsection (a)(2)(A) shall not be 
     required to begin before January 1, 1999'' after ``Act''.
                                 ______
                                 

                COLLINS (AND OTHERS) AMENDMENT NO. 2381

  Ms. COLLINS (for herself, Mr. DeWine, Mr. Sessions, and Mr. McCain) 
proposed an amendment to the bill, H.R. 2676, supra; as follows:

       At the end of subtitle H of title III, add the following:

     SEC. ____. REPORTING REQUIREMENTS IN CONNECTION WITH 
                   EDUCATION TAX CREDIT.

       (a) Amounts to be Reported.--Subparagraph (C) of section 
     6050S(b)(2) is amended--
       (1) in clause (i), by inserting ``and any grant amount 
     received by such individual and processed through the 
     institution during such calendar year'' after ``calendar 
     year'',
       (2) in clause (ii), by inserting ``by the person making 
     such return'' after ``year'', and
       (3) in clause (iii), by inserting ``and'' at the end.
       (b) Effective Date.--The amendments made by this section 
     shall apply to returns required to be filed with respect to 
     taxable years beginning after December 31, 1998.
                                 ______
                                 

                        ROTH AMENDMENT NO. 2382

  Mr. ROTH proposed an amendment to the bill, H.R. 2676, supra; as 
follows:

       On page 202, between lines 5 and 6, insert the following:
       ``(iv) Coordination with report of treasury inspector 
     general for tax administration.--To the extent that 
     information required to be reported under clause (ii) is also 
     required to be reported under paragraph (1) or (2) of 
     subsection (d) by the Treasury Inspector General for Tax 
     Administration, the National Taxpayer Advocate shall not 
     contain such information in the report submitted under such 
     clause.
       On page 204, line 1, strike ``directly''.
       On page 206, line 23, strike ``(2)'' and insert ``(3)(A)''.
       On page 207, line 9, insert ``by the Internal Revenue 
     Service or the Inspector General'' before ``during''.
       On page 207, line 20, strike ``(B)'' and insert ``(A)''.
       On page 207, lines 24 and 25, strike ``not less than 1 
     percent'' and insert ``a statistically valid sample''.
       On page 252, line 25, insert ``or taxpayer representative'' 
     after ``taxpayer''.
       On page 253, line 1, insert ``, taxpayer representative,'' 
     after ``taxpayer''.
       On page 253, line 5, insert ``or taxpayer representative'' 
     after ``taxpayer''.
       On page 253, line 6, insert ``, taxpayer representative,'' 
     after ``taxpayer''.
       On page 253, line 12, insert ``, taxpayer representative,'' 
     after ``taxpayer''.
       On page 254, lines 14 and 15, strike ``and their immediate 
     supervisors''.
       On page 254, lines 17 and 18, strike ``individuals 
     described in paragraph (1)'' and insert ``such employees''.
       On page 322, line 11, strike ``subsection'' and insert 
     ``section''.
                                 ______
                                 

                 GRAHAM (AND OTHERS) AMENDMENT NO. 2383

  Mr. ROTH (for Mr. Graham, for himself, Mr. Nickles, and Ms. Moseley-
Braun) proposed an amendment to the bill, H.R. 2676, supra; as follows:

       Beginning on page 307, line 6, strike all through page 308, 
     line 3, and insert:

     SEC. 3301. ELIMINATION OF INTEREST RATE DIFFERENTIAL ON 
                   OVERLAPPING PERIODS OF INTEREST ON TAX 
                   OVERPAYMENTS AND UNDERPAYMENTS.

       (a) In General.--Section 6621 (relating to determination of 
     rate of interest) is amended by adding at the end the 
     following new subsection:
       ``(d) Elimination of Interest on Overlapping Periods of Tax 
     Overpayments and Underpayments.--To the extent that, for any 
     period, interest is payable under subchapter A and allowable 
     under subchapter B on equivalent underpayments and 
     overpayments by the same taxpayer of tax imposed by this 
     title, the net rate of interest under this section on such 
     amounts shall be zero for such period.''.
       (b) Conforming Amendment.--Subsection (f) of section 6601 
     (relating to satisfaction by credits) is amended by adding at 
     the end the following new sentence: ``The preceding sentence 
     shall not apply to the extent that section 6621(d) 
     applies.''.
       (c) Effective Dates.--
       (1) In general.--Except as provided under paragraph (2), 
     the amendments made by this section shall apply to interest 
     for periods beginning after the date of the enactment of this 
     Act.
       (2) Special rule.--Subject to any applicable statute of 
     limitation not having expired with regard to either a tax 
     underpayment or a tax overpayment, the amendments made by 
     this section shall apply to interest for periods beginning 
     before the date of the enactment of this Act if the 
     taxpayer--
       (A) reasonably identifies and establishes periods of such 
     tax overpayments and underpayments for which the zero rate 
     applies, and
       (B) not later than December 31, 1999, requests the 
     Secretary of the Treasury to apply section 6621(d) of the 
     Internal Revenue Code of 1986, as added by subsection (a), to 
     such periods.

     SEC. 3301A. PROPERTY SUBJECT TO A LIABILITY TREATED IN SAME 
                   MANNER AS ASSUMPTION OF LIABILITY.

       (a) Repeal of Property Subject to a Liability Test.--
       (1) Section 357.--Section 357(a) (relating to assumption of 
     liability) is amended by striking ``, or acquires from the 
     taxpayer property subject to a liability'' in paragraph (2).
       (2) Section 358.--Section 358(d)(1) (relating to assumption 
     of liability) is amended by striking ``or acquired from the 
     taxpayer property subject to a liability''.
       (3) Section 368.--
       (A) Section 368(a)(1)(C) is amended by striking ``, or the 
     fact that property acquired is subject to a liability,''.
       (B) The last sentence of section 368(a)(2)(B) is amended by 
     striking ``, and the amount of any liability to which any 
     property acquired from the acquiring corporation is 
     subject,''.
       (b) Clarification of Assumption of Liability.--Section 
     357(c) is amended by adding at the end the following new 
     paragraph:
       ``(4) Determination of amount of liability assumed.--For 
     purposes of this section, section 358(d), section 
     368(a)(1)(C), and section 368(a)(2)(B)--
       ``(A) a liability shall be treated as having been assumed 
     to the extent, as determined on the basis of facts and 
     circumstances, the transferor is relieved of such liability 
     or any portion thereof (including through an indemnity 
     agreement or other similar arrangement), and
       ``(B) in the case of the transfer of any property subject 
     to a nonrecourse liability, unless the facts and 
     circumstances indicate otherwise, the transferee shall be 
     treated as assuming with respect to such property a ratable 
     portion of such liability determined on the basis of the 
     relative fair market values (determined without regard to 
     section 7701(g)) of all assets subject to such liability.''
       (c) Application to Provisions Other Than Subchapter C.--
       (1) Section 584.--Section 584(h)(3) is amended--
       (A) by striking ``, and the fact that any property 
     transferred by the common trust fund is subject to a 
     liability,'' in subparagraph (A),
       (B) by striking clause (ii) of subparagraph (B) and 
     inserting:
       ``(ii) Assumed liabilities.--For purposes of clause (i), 
     the term `assumed liabilities' means any liability of the 
     common trust fund assumed by any regulated investment company 
     in connection with the transfer referred to in paragraph 
     (1)(A).
       ``(C) Assumption.--For purposes of this paragraph, in 
     determining the amount of any liability assumed, the rules of 
     section 357(c)(4) shall apply.''
       (2) Section 1031.--The last sentence of section 1031(d) is 
     amended--
       (A) by striking ``assumed a liability of the taxpayer or 
     acquired from the taxpayer property subject to a liability'' 
     and inserting ``assumed (as determined under section 
     357(c)(4)) a liability of the taxpayer'', and
       (B) by striking ``or acquisition (in the amount of the 
     liability)''.
       (d) Conforming Amendments.--
       (1) Section 351(h)(1) is amended by striking ``, or 
     acquires property subject to a liability,''.
       (2) Section 357 is amended by striking ``or acquisition'' 
     each place it appears in subsection (a) or (b).
       (3) Section 357(b)(1) is amended by striking ``or 
     acquired''.
       (4) Section 357(c)(1) is amended by striking ``, plus the 
     amount of the liabilities to which the property is 
     subject,''.
       (5) Section 357(c)(3) is amended by striking ``or to which 
     the property transferred is subject''.
       (6) Section 358(d)(1) is amended by striking ``or 
     acquisition (in the amount of the liability)''.
       (e) Effective Date.--The amendments made by this section 
     shall apply to transfers after the date of the enactment of 
     this Act.
                                 ______
                                 

                       STEVENS AMENDMENT NO. 2384

  Mr. ROTH (for Mr. Stevens) proposed an amendment to the bill, H.R. 
2676, supra; as follows:

       On page 355, insert after line 19 the following:
       (d) State Fish and Wildlife Permits.--(1) With respect to 
     permits issued by a State and required under State law for 
     the harvest of fish or wildlife in the trade or business of 
     an individual taxpayer, ``other assets'' as used in section 
     3445 shall include future income that may be derived by such 
     taxpayer from the commercial sale of fish or wildlife under 
     such permit.
       (2) The preceding paragraph may not be construed to 
     invalidate or in any way prejudice any assertion that the 
     privilege embodied in such permits is not property or a right 
     to property under the Internal Revenue Code.
                                 ______
                                 

                BINGAMAN (AND CHAFEE) AMENDMENT NO. 2385

  Mr. ROTH (for Mr. Bingaman, for himself and Mr. Chafee) proposed an 
amendment to the bill, H.R. 2676, supra; as follows:

       On page 375, line 11, strike the period and insert ``, 
     including volunteer income tax assistance programs, and to 
     provide funds for

[[Page S4547]]

     training and technical assistance to support such clinics and 
     programs.''
       On page 375, line 22, strike ``or''.
       On page 376, line 2, strike the period and insert ``, or''.
       On page 376, between lines 2 and 3, insert:

       ``(III) provides tax preparation assistance and tax 
     counseling assistance to low income taxpayers, such as 
     volunteer income tax assistance programs.''

       On page 376, line 20, strike ``and''.
       On page 376, line 25, strike the period and insert ``and''.
       On page 376, after line 25, insert:
       ``(C) a volunteer income tax assistance program which is 
     described in section 501(c) and exempt from tax under section 
     501(a) and which provides tax preparation assistance and tax 
     counseling assistance to low income taxpayers.''
       On page 377, line 9, strike ``$3,000,000'' and insert 
     ``$6,000,000''.
       On page 377, line 11, after the end period, insert ``Not 
     more than 7.5 percent of the amount available shall be 
     allocated to training and technical assistance programs.''
       On page 377, line 15, insert ``, except that larger grants 
     may be made for training and technical assistance programs'' 
     after ``$100,000''.
       On page 378, line 16, insert ``(other than a clinic 
     described in paragraph (2)(C))'' after ``clinic''.
       On page 396, strike lines 18 through 20, and insert 
     ``Finance of the Senate. The report shall include any 
     recommendations--
       (A) for reducing the complexity of the administration of 
     Federal tax laws, and
       (B) for repeal or modification of any provision the 
     Commissioner believes adds undue and unnecessary complexity 
     to the administration of the Federal tax laws.

                          ____________________