[Congressional Record Volume 161, Number 74 (Thursday, May 14, 2015)]
[Senate]
[Page S2943]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]

  SA 1242. Mr. BROWN submitted an amendment intended to be proposed to 
amendment SA 1221 proposed by Mr. Hatch to the bill H.R. 1314, to amend 
the Internal Revenue Code of 1986 to provide for a right to an 
administrative appeal relating to adverse determinations of tax-exempt 
status of certain organizations; as follows:

       On page 118, strike lines 19 through 23, and insert the 
     following:
       (b) Training Funds.--
       (1) In general.--Section 236(a)(2)(A) of the Trade Act of 
     1974 (19 U.S.C. 2296(a)(2)(A)) is amended by striking ``shall 
     not exceed'' and all that follows and inserting ``shall not 
     exceed $575,000,000 for each of fiscal years 2015 through 
     2021.''.
       (2) Offset.--
       (A) Clarification of 6-year statute of limitations in case 
     of overstatement of basis.--Subparagraph (B) of Section 
     6501(e)(1) of the Internal Revenue Code of 1986 is amended--
       (i) by striking ``and'' at the end of clause (i), by 
     redesignating clause (ii) as clause (iii), and by inserting 
     after clause (i) the following new clause:
       ``(ii) An understatement of gross income by reason of an 
     overstatement of unrecovered cost or other basis is an 
     omission from gross income;'', and
       (ii) by inserting ``(other than in the case of an 
     overstatement of unrecovered cost or other basis)'' in clause 
     (iii) (as so redesignated) after ``In determining the amount 
     omitted from gross income'', and
       (iii) by inserting ``AMOUNT OMITTED FROM'' after 
     ``DETERMINATION OF'' in the heading thereof.
       (B) Effective date.--The amendments made by subparagraph 
     (A) shall apply to--
       (i) returns filed after the date of the enactment of this 
     Act; and
       (ii) returns filed on or before such date if the period 
     specified in section 6501 of the Internal Revenue Code of 
     1986 (determined without regard to such amendments for 
     assessment of the taxes with respect to which such return 
     relates has not expired as of such date.
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