[House Report 118-646]
[From the U.S. Government Publishing Office]


                                                 Union Calendar No. 543
118th Congress   }                                     {   Report
                         HOUSE OF REPRESENTATIVES
 2d Session      }                                     {   118-646
======================================================================



SUBMISSION TO THE U.S. HOUSE OF REPRESENTATIVES OF DOCUMENTS PROTECTED 
                UNDER INTERNAL REVENUE CODE SECTION 6103

                               __________

                              R E P O R T

                                 OF THE

                      COMMITTEE ON WAYS AND MEANS

                        HOUSE OF REPRESENTATIVES

                             together with

                            DISSENTING VIEWS

                  [GRAPHIC NOT AVAILABLE IN TIFF FORMAT]


 September 3, 2024.--Committed to the Committee of the Whole House on 
             the State of the Union and ordered to printed
             
               		       __________
               		       
               		       
               	    U.S. GOVERNMENT PUBLISHING OFFICE	       
               
56-613			    WASHINGTON : 2024              
             

                          LETTER OF SUBMITTAL

                              ----------                              

                                  House of Representatives,
                                 Washington, DC, September 3, 2024.
    Dear Mr. Speaker: On May 22, 2024, by a vote of 23 to 14, 
the Committee on Ways and Means voted to submit documents 
protected under Internal Revenue Code Section 6103. Minority 
views are included.
            Sincerely,
                                               Jason Smith,
                             Chairman, Committee on Ways and Means.




                                                 Union Calendar No. 543
118th Congress   }                                     {   Report
                         HOUSE OF REPRESENTATIVES
 2d Session      }                                     {   118-646
======================================================================



 
SUBMISSION TO THE U.S. HOUSE OF REPRESENTATIVES OF DOCUMENTS PROTECTED 
                UNDER INTERNAL REVENUE CODE SECTION 6103

                                _______
                                

 September 3, 2024.--Committed to the Committee of the Whole House on 
            the State of the Union and ordered to be printed

                                _______
                                

Mr. Smith of Missouri, from the Committee on Ways and Means, submitted 
                             the following

                              R E P O R T

                             together with

                            DISSENTING VIEWS

                                CONTENTS

  I. SUMMARY AND BACKGROUND...........................................1
          A. Purpose and Summary.................................     1
          B. Background on The Committee's Jurisdiction and 
              Statutory Authority................................     2
          C. Background on The Committee's Work..................     2
 II. EXPLANATION OF SUBMITTED MATERIALS...............................5
          A. Background on the Submitted Materials...............     5
          B. Description of the Submitted Materials..............     6
          C. Description of Committee Redactions.................     6
III. VOTES OF THE COMMITTEE...........................................6
 IV. DISSENTING VIEWS.................................................9
  V. ATTACHMENTS.....................................................12

                       I. SUMMARY AND BACKGROUND


                         A. Purpose and Summary

    The Committee on Ways and Means (``Committee'') met in 
closed executive session on May 22, 2024, to consider materials 
protected by 26 U.S.C. Sec. 6103 (``Section 6103''), comprised 
of the following.
    Mr. Joseph Ziegler (``Mr. Ziegler''), an Internal Revenue 
Service (``IRS'') Criminal Investigator, provided three 
affidavits, with related exhibits on March 12, 2024, and May 
14, 2024. Mr. Gary Shapley (``Mr. Shapley''), another IRS 
Criminal Investigator, also provided one affidavit with a 
related exhibit on May 14, 2024. The Committee considered the 
documents during the closed executive session.

 B. Background on The Committee's Jurisdiction and Statutory Authority

    The Committee has sole jurisdiction in the United States to 
originate federal tax legislation and has oversight authority 
over tax administration by the IRS and the U.S. Department of 
the Treasury.\1\ Under Section 6103, there is a ``general rule 
that [tax] returns and return information are 
confidential.''\2\ Therefore, ``[r]eturns and return 
information cannot be disclosed unless a specific exception for 
such disclosure is provided for in the Code.''\3\ There are ``a 
number of specific exceptions to the general rule of 
confidentiality'' in Section 6103, including ``authorizations 
to furnish information to Congress, the Department of Justice, 
and certain designees of the taxpayer pursuant to taxpayer 
consent.''\4\
---------------------------------------------------------------------------
    \1\Article I, Section 7, U.S. Constitution; H. Comm. on Ways and 
Means, About, https://waysandmeans.house.gov/about/.
    \2\Joint Committee on Taxation, Background Regarding the 
Confidentiality and Disclosure of Federal Tax Returns (JCX-3-19) (Feb. 
4, 2019), https://www.jct.gov/getattachment/4c176272-a1d4-468e-ba68-
1c1c51a11d61/x-3-19-5159.pdf.
    \3\Id.
    \4\Id.
---------------------------------------------------------------------------
    Section 6103 also authorizes the Chairmen of the House 
Committee on Ways and Means, the Senate Committee on Finance, 
and the Joint Committee on Taxation to receive returns and 
return information; and the Chairmen of those Committees, along 
with the Chief of Staff of the Joint Committee on Taxation, may 
``designate examiners and agents to inspect returns and return 
information.''\5\ Section 6103 also contains a whistleblower 
provision:
---------------------------------------------------------------------------
    \5\Id.; 26 U.S.C. Sec. 6103(f)(4)(A).

          Any person who otherwise has or had access to any 
        return or return information under this section may 
        disclose such return or return information to a 
        committee referred to in paragraph (1) or any 
        individual authorized to receive or inspect information 
        under paragraph (4)(A) if such person believes such 
        return or return information may relate to possible 
        misconduct, maladministration, or taxpayer abuse.\6\
---------------------------------------------------------------------------
    \6\6 U.S.C. Sec. 6103(f)(5).

    Moreover, any return or return information obtained by or 
on behalf of the Committees ``may be submitted by the committee 
to either the Senate or the House of Representatives, or to 
both. Such submission does not require the Senate or House of 
Representatives to be sitting in closed executive session.''\7\
---------------------------------------------------------------------------
    \7\26 U.S.C. Sec. 6103(f)(4)(A); Joint Committee on Taxation, 
Background Regarding the Confidentiality and Disclosure of Federal Tax 
Returns (JCX-93-19) (Feb. 4, 2019), https://www.jct.gov/getattachment/
4c176272-a1d4-468e-ba68-1c1c51a11d61/x-3-19-5159.pdf.
---------------------------------------------------------------------------

                 C. Background on The Committee's Work

    Chairman Smith, Ranking Member Neal, and the Chairs and 
Ranking Members of other House and Senate Committees received a 
letter on April 19, 2023, from counsel for an IRS Criminal 
Supervisory Special Agent, who was later identified as Mr. 
Shapley.\8\ That letter outlined, in very general terms, the 
nature of information Mr. Shapley wished to share with the 
Committee, including information that would:
---------------------------------------------------------------------------
    \8\Statement from Chairman Smith on IRS Whistleblower Outreach, H. 
Comm. on Ways and Means (Apr. 19, 2023), https://
waysandmeans.house.gov/statement-from-chairman-smith-on-irs-
whistleblower-outreach/.
---------------------------------------------------------------------------
          1) Contradict sworn testimony provided to Congress by 
        a senior political official;
          2) Identify unmitigated conflicts of interest; and
          3) Provide examples of preferential treatment based 
        on political considerations.
    Counsel for Mr. Shapley offered to provide a proffer to the 
Committee to outline the nature of the testimony Mr. Shapley 
could provide. The Chairman properly authorized counsel to do 
so under Section 6103.
    On May 5, 2023, Committee staff received that attorney 
proffer, which disclosed that the subject of the investigation 
was R. Hunter Biden. Majority and minority staff were 
designated by Chairman Smith under Section 6103 to receive the 
information; both majority and minority staff were present at 
the attorney proffer and were afforded equal opportunity to ask 
questions. After receiving the proffer, a voluntary interview 
of Mr. Shapley was scheduled for later in May.
    On May 15, 2023, the Committee received a letter from Mr. 
Shapley's legal counsel notifying the Committee that he and his 
entire IRS investigative team had been removed from the ongoing 
and sensitive investigation about which Mr. Shapley sought to 
make a disclosure to Congress.\9\ The letter noted that Mr. 
Shapley was informed that the removal occurred at the request 
of the U.S. Department of Justice (``DOJ'').\10\ Following that 
removal, the Committee learned that another IRS employee had 
retained counsel and had interest in providing additional 
relevant information to the Committee.
---------------------------------------------------------------------------
    \9\Letter from Mark D. Lytle and Tristan Leavitt, to The Hon. Jason 
Smith, Chairman, H. Comm. on Ways and Means, The Hon. Jim Jordan, 
Chairman, H. Comm. on the Judiciary, et al. (May 15, 2023).
    \10\Id.
---------------------------------------------------------------------------
    On May 22, 2023, the Committee received a letter from Mr. 
Shapley's legal counsel alleging that the IRS had taken further 
actions against Mr. Shapley.\11\
---------------------------------------------------------------------------
    \11\Letter from Tristan Leavitt and Mark D. Lytle to The Hon. Jason 
Smith, Chairman, H. Comm on Ways and Means, et al. (May 22, 2023).
---------------------------------------------------------------------------
    On May 24, 2023, the Committee received a letter from an 
IRS Criminal Investigator's legal counsel noting that 
Whistleblower 2, who later identified himself as Mr. Ziegler, 
shared the concerns about the management of the high-profile 
case raised by Mr. Shapley.\12\ The letter also notes that 
despite Mr. Ziegler's good faith efforts to engage in a 
dialogue with supervisors at the IRS about this case and the 
management of the case, to date, this has resulted in no 
constructive engagement.\13\ Rather, IRS management responded 
in a manner that raised significant alarm for Mr. Ziegler of 
possible retaliation.
---------------------------------------------------------------------------
    \12\Letter from Dean Zerbe to The Hon. Jason Smith, Chairman, and 
The Hon. Richard Neal, Ranking Member, H. Comm on Ways and Means, et 
al. (May 22, 2023).
    \13\Id.
---------------------------------------------------------------------------
    On May 26, 2023, and June 1, 2023, Committee staff 
conducted voluntary transcribed interviews of Mr. Shapley and 
Mr. Ziegler. Each interview lasted for approximately seven 
hours. Majority and minority staff had equal opportunity to ask 
questions of the whistleblowers and were able to ask questions 
until none remained.
    On June 22, 2023, the Committee held an executive session 
to consider materials protected by Section 6103, including the 
transcripts of the transcribed interviews of the two 
whistleblowers and two supplemental documents submitted by the 
whistleblowers.\14\ The minority also requested that the 
Committee include and consider a June 7, 2023, letter from IRS 
Commissioner Daniel Werfel to Chairman Smith.\15\ The Committee 
voted to submit those materials to the U.S. House of 
Representatives and thereby make public all five documents. The 
Committee also voted to make a transcript of the closed 
executive session public.
---------------------------------------------------------------------------
    \14\H. Comm. on Ways and Means, Smith: Testimony of IRS Employees 
Reveals Biden IRS, DOJ Interfered in Tax Investigation of Hunter Biden, 
Revealing Preferential Treatment for Wealthy and Politically Connected 
(June 22, 2023), https://gop-waysandmeans.house.gov/smith-testimony-of-
irs-employees-reveals-biden-irs-doj-interfered-in-tax-investigation-of-
hunter-biden-revealing-preferential-treatment-for-wealthy-and-
politically-connected/.
    \15\Id.
---------------------------------------------------------------------------
    On June 29, 2023, the Chairmen of the Committee on Ways and 
Means, the Committee on the Judiciary, and the Committee on 
Oversight and Accountability sent letters requesting interviews 
with 13 federal government employees--including two IRS 
officials--likely to have information relevant to Mr. Shapley's 
and Mr. Ziegler's allegations.\16\
---------------------------------------------------------------------------
    \16\Letter from Chairmen Jim Jordan, Jason Smith, and James Comer, 
to Daniel Werfel, Commissioner, Internal Revenue Service (June 29, 
2023).
---------------------------------------------------------------------------
    The DOJ and IRS did not initially make any of those 
individuals available for interviews on a voluntary basis. 
Chairman Smith therefore issued deposition subpoenas to the two 
IRS employees--Michael Batdorf and Darrel Waldon.\17\ After the 
subpoenas were issued, the IRS agreed to make Mr. Batdorf and 
Mr. Waldon available for voluntary transcribed interviews on a 
limited set of topics. Specifically, in advance of their 
interviews with the Committee, Mr. Batdorf and Mr. Waldon were 
directed by the IRS not to answer certain questions relevant to 
the Committee's investigation. During the interviews, IRS 
lawyers intervened on numerous occasions to instruct Mr. 
Batdorf and Mr. Waldon not to answer certain questions.\18\
---------------------------------------------------------------------------
    \17\H. Comm. on Ways and Means, Ways and Means, Judiciary 
Committees Issue Subpoenas Compelling Witness Testimony on Political 
Interference and Preferential Treatment in Hunter Biden Investigation 
(Aug. 21, 2023), https://waysandmeans.house.gov/ways-and-means-
judiciary-committees-issue-subpoenas-compelling-witness-testimony-on-
political-interference-and-preferential-treatment-in-hunter-biden-
investigation/.
    \18\See e.g., Memorandum for Darrell Waldon, Director, Advanced 
Analytics & Innovation, Criminal Investigation, from Daniel I. Werfel, 
Commissioner, Subject: Testimony Authorization (Sept. 7, 2023); 
Memorandum for Michael Batdorf, Director of Field Operations, Southern 
Area, Criminal Investigation, from Daniel I. Werfel, Commissioner, 
Subject: Testimony Authorization (Sept. 11, 2023); Transcribed 
Interview of Darrell Waldon, Director, Advanced Analytics & Innovation, 
Internal Revenue Service Criminal Investigation at 9 (Sept. 8, 2023); 
Transcribed Interview of Michael Batdorf, Director of Field Operations, 
Internal Revenue Service Criminal Investigation at 8 (Sept. 12, 2023).
---------------------------------------------------------------------------
    The Committee has also requested documents and information 
from the DOJ, but very few responsive documents have been 
provided. In addition, the Committee has sought information 
from the Treasury Inspector General for Tax Administration 
(``TIGTA''), the DOJ Inspector General (``DOJ OIG''), and the 
Office of Special Counsel (``OSC''), which is an independent 
agency that protects federal employees from prohibited 
personnel practices.
    On July 19, 2023, Mr. Shapley and Mr. Ziegler testified 
before the Oversight and Accountability Committee, where they 
stated that they could not answer certain questions in an open 
setting but would provide the Committee with additional 
information under Section 6103.\19\ After the Oversight and 
Accountability Committee hearing on July 19, 2023, Mr. Shapley 
and Mr. Ziegler began providing additional Section 6103 
materials to the Committee.
---------------------------------------------------------------------------
    \19\H. Comm. on Oversight and Accountability, Hearing with IRS 
Whistleblowers About the Biden Criminal Investigation (July 19, 2023), 
https://oversight.house.gov/hearing/hearing-with-irs-whistleblowers-
about-the-biden-criminal-investigation/.
---------------------------------------------------------------------------
    On September 27, 2023, the Committee held an executive 
session to consider materials protected by Section 6103, 
including a Committee on Ways and Means Report, five affidavits 
from Mr. Ziegler with accompanying exhibits, three supplemental 
disclosures from Mr. Shapley with accompanying attachments, and 
the transcript of the closed executive session. The Committee 
voted to submit those materials to the U.S. House of 
Representatives and thereby make public all documents.
    On October 30, 2023, Mr. Ziegler provided additional 
Section 6103 materials to the Committee. The production of 
documents was provided by Mr. Ziegler to Committee majority and 
minority staff designated under Section 6103. All materials 
provided in this production were considered by the Committee on 
December 5, 2023.
    In addition, Mr. Shapley and Mr. Ziegler testified before 
the Committee in executive session. Therefore, the Committee 
also put forward Mr. Shapley and Mr. Ziegler's testimony, and 
the slides Mr. Ziegler submitted to the Committee that 
accompanied his testimony. The Committee also voted to release 
the transcripts of both executive sessions.

                 II. EXPLANATION OF SUBMITTED MATERIALS


                A. Background on the Submitted Materials

    The Committees on Oversight and Accountability and the 
Judiciary (together with the Committee on Ways and Means, the 
``Committees'') have been conducting investigations into the 
allegations of the whistleblowers with regard to the federal 
government's handling of the Hunter Biden investigation and 
President Joe Biden's potential involvement in Hunter Biden's 
activities.
    As part of the investigation, the Committees on Oversight 
and Accountability and Judiciary issued a subpoena to Hunter 
Biden for a deposition to be conducted on December 13, 
2023.\20\ On December 13, Hunter Biden failed to comply with 
the deposition subpoena, violating federal law.\21\ Instead, he 
appeared on Capitol grounds where he read a short statement 
without taking any questions.
---------------------------------------------------------------------------
    \20\H. Comm. on Oversight and Accountability, Comer: We will Not 
Provide Hunter Biden Special Treatment for Defying Lawful Subpoenas 
Because of His Last Name (Jan. 10, 2024), https://oversight.house.gov/
release/comer-we-will-not-provide-hunter-biden-special-treatment-for-
defying-lawful-subpoenas-because-of-his-last-name/.
    \21\See 2 U.S.C. Sec. 192 (``Every person who having been summoned 
as a witness by the authority of either House of Congress to give 
testimony . . . upon any matter under inquiry before either House . . . 
or any committee of either House of Congress, willfully makes default . 
. . shall be deemed guilty of a misdemeanor. . . .'').
---------------------------------------------------------------------------
    Following Hunter Biden's defiance of the Congressional 
subpoena, and only under threat of criminal penalty, did Hunter 
Biden's attorney reach out to negotiate an appearance with 
Members of Congress.\22\ Under threat of being held in contempt 
of Congress for failing to appear, Hunter Biden reengaged with 
the Committees and finally agreed to appear. On February 14, 
2024, the House Oversight and Judiciary Committees reissued 
subpoenas for Mr. Biden to appear at a deposition on February 
28, 2024.\23\ Mr. Biden finally did appear to answer questions. 
A transcript of his deposition was publicly released on 
February 29, 2024.
---------------------------------------------------------------------------
    \22\H. Comm. on Oversight and Accountability, Comer Announces 
Markup of Resolution to Hold Hunter Biden in Contempt of Congress (Jan. 
5, 2024), https://oversight.house.gov/release/comer-announces-markup-
of-resolution-to-hold-hunter-biden-in-contempt-of-congress/.
    \23\Deposition Interview of Robert Hunter Biden. (Feb. 28, 2024), 
https://oversight.house.gov/wp-content/uploads/2024/02/Hunter-Biden-
Transcript_Redacted.pdf.
---------------------------------------------------------------------------
    Mr. Ziegler reviewed Mr. Biden's answers subsequent to the 
release of the deposition. During his review, Mr. Ziegler found 
numerous instances where Hunter Biden may have lied under oath. 
Therefore, Mr. Ziegler provided the Committee with additional 
materials protected under Section 6103. According to Mr. 
Ziegler's affidavit, the materials provided to the Committee is 
a supplement and in response to ``admissions and claims against 
Gary Shapley and [Mr. Ziegler] made by [Hunter Biden] and his 
counsel during [Hunter Biden's] most recent congressional 
testimony on February 28, 2024.''\24\
---------------------------------------------------------------------------
    \24\Joseph Ziegler, Affidavit 9 at 1.
---------------------------------------------------------------------------
    Additionally, Mr. Shapley provided an affidavit with a 
single attachment with more evidence of the DOJ's obstruction 
of the IRS investigation into Hunter Biden.

               B. Description of the Submitted Materials

    The documents presented during executive session for the 
Committee's consideration included the following:
          1. Affidavit 8 from Mr. Ziegler which includes 8 
        exhibits for further clarification.
          2. Affidavit 9 from Mr. Ziegler which includes 3 
        exhibits for further clarification
          3. Affidavit 10 from Mr. Ziegler which includes 16 
        exhibits for further clarification.
          4. Affidavit from Mr. Shapley which includes 1 
        exhibit for further clarification.
    Additionally, the transcript from the executive session is 
included in the documents, as the Committee voted, by voice, to 
release the transcript.

                 C. Description of Committee Redactions

    Mr. Joseph Ziegler provided documents to the Committee with 
numerous redactions. The Committee's majority and minority 
staff reviewed the materials and minority staff had the 
opportunity to propose additional redactions or suggest 
additions to the materials for consideration. The Committee 
made minimal additional redactions to the materials, including 
certain phone numbers, email addresses, and account numbers.

                      III. VOTES OF THE COMMITTEE

    Pursuant to clause 3(b) of rule XIII of the Rules of the 
House of Representatives, the following statements are made 
concerning the vote of the Committee in its consideration of 
materials that were considered by the Committee during the 
Executive Session.
    A motion, offered by Mr. Smith of Nebraska, to make public 
the transcript of the executive session proceedings should the 
Committee vote to submit to the House any information. The 
motion was agreed to by unanimous consent. See Attachment A at 
end of report.
    A motion, pursuant to clause 2(g)(1) of House Rule 11, that 
the Committee proceed to a closed executive session, offered by 
Mr. Schweikert. The motion was agreed to by a roll call vote of 
36 yeas to 0 nays (with quorum being present). The vote was as 
follows:

----------------------------------------------------------------------------------------------------------------
          Representative             Yea      Nay     Present      Representative      Yea      Nay     Present
----------------------------------------------------------------------------------------------------------------
Mr. Smith (MO)...................       X   .......  .........  Mr. Neal...........       X   .......  .........
Mr. Buchanan.....................  .......  .......  .........  Mr. Doggett........       X   .......  .........
Mr. Smith (NE)...................       X   .......  .........  Mr. Thompson.......       X   .......  .........
Mr. Kelly........................       X   .......  .........  Mr. Larson.........       X   .......  .........
Mr. Schweikert...................       X   .......  .........  Mr. Blumenauer.....  .......  .......  .........
Mr. LaHood.......................       X   .......  .........  Mr. Pascrell.......       X   .......  .........
Dr. Wenstrup.....................       X   .......  .........  Mr. Davis..........       X   .......  .........
Mr. Arrington....................       X   .......  .........  Ms. Sanchez........       X   .......  .........
Dr. Ferguson.....................       X   .......  .........  Ms. Sewell.........       X   .......  .........
Mr. Estes........................       X   .......  .........  Ms. DelBene........       X   .......  .........
Mr. Smucker......................       X   .......  .........  Ms. Chu............       X   .......  .........
Mr. Hern.........................       X   .......  .........  Ms. Moore..........  .......  .......  .........
Ms. Miller.......................       X   .......  .........  Mr. Kildee.........       X   .......  .........
Dr. Murphy.......................  .......  .......  .........  Mr. Beyer..........       X   .......  .........
Mr. Kustoff......................       X   .......  .........  Mr. Evans..........  .......  .......  .........
Mr. Fitzpatrick..................       X   .......  .........  Mr. Schneider......       X   .......  .........
Mr. Steube.......................       X   .......  .........  Mr. Panetta........       X   .......  .........
Ms. Tenney.......................       X   .......  .........  Mr. Gomez..........  .......  .......  .........
Mrs. Fischbach...................       X   .......  .........
Mr. Moore........................  .......  .......  .........
Mrs. Steel.......................       X   .......  .........
Ms. Van Duyne....................       X   .......  .........
Mr. Feenstra.....................       X   .......  .........
Ms. Malliotakis..................       X   .......  .........
Mr. Carey........................       X   .......  .........
----------------------------------------------------------------------------------------------------------------

    Mr. Schweikert's motion to submit to the House of 
Representatives documents protected under Internal Revenue Code 
Section 6103 was ordered favorably reported to the House of 
Representatives by a roll call vote of 23 yeas to 14 nays (with 
a quorum being present). The vote was as follows:

----------------------------------------------------------------------------------------------------------------
          Representative             Yea      Nay     Present      Representative      Yea      Nay     Present
----------------------------------------------------------------------------------------------------------------
Mr. Smith (MO)...................       X   .......  .........  Mr. Neal...........  .......       X   .........
Mr. Buchanan.....................  .......  .......  .........  Mr. Doggett........  .......       X   .........
Mr. Smith (NE)...................       X   .......  .........  Mr. Thompson.......  .......       X   .........
Mr. Kelly........................       X   .......  .........  Mr. Larson.........  .......       X   .........
Mr. Schweikert...................       X   .......  .........  Mr. Blumenauer.....  .......  .......  .........
Mr. LaHood.......................       X   .......  .........  Mr. Pascrell.......  .......       X   .........
Dr. Wenstrup.....................       X   .......  .........  Mr. Davis..........  .......       X   .........
Mr. Arrington....................       X   .......  .........  Ms. Sanchez........  .......       X   .........
Dr. Ferguson.....................       X   .......  .........  Ms. Sewell.........  .......       X   .........
Mr. Estes........................       X   .......  .........  Ms. DelBene........  .......       X   .........
Mr. Smucker......................       X   .......  .........  Ms. Chu............  .......       X   .........
Mr. Hern.........................       X   .......  .........  Ms. Moore..........  .......  .......  .........
Ms. Miller.......................       X   .......  .........  Mr. Kildee.........  .......       X   .........
Dr. Murphy.......................  .......  .......  .........  Mr. Beyer..........  .......       X   .........
Mr. Kustoff......................       X   .......  .........  Mr. Evans..........  .......  .......  .........
Mr. Fitzpatrick..................       X   .......  .........  Mr. Schneider......  .......       X   .........
Mr. Steube.......................       X   .......  .........  Mr. Panetta........  .......       X   .........
Ms. Tenney.......................       X   .......  .........  Mr. Gomez..........  .......  .......  .........
Mrs. Fischbach...................       X   .......  .........
Mr. Moore........................       X   .......  .........
Mrs. Steel.......................       X   .......  .........
Ms. Van Duyne....................       X   .......  .........
Mr. Feenstra.....................       X   .......  .........
Ms. Malliotakis..................       X   .......  .........
Mr. Carey........................       X   .......  .........
----------------------------------------------------------------------------------------------------------------


                          IV. DISSENTING VIEWS

      ``DOCUMENTS PROTECTED UNDER SECTION 6103'' RELATING TO IRS 
                             WHISTLEBLOWERS

    For over a year the Majority has been desperate to uncover 
evidence of wrongdoing by President Biden or his Administration 
to give credibility to their baseless impeachment inquiry. Yet, 
there has been no shred of evidence of wrongdoing or political 
interference by President Biden or his Administration. Nor has 
there been any evidence of maladministration by the Internal 
Revenue Service (IRS). This was the fourth executive session 
convened by the Majority this Congress and another dead end. 
The impeachment inquiry is based on recycled, debunked 
conspiracy theories, and it must conclude. Thus, the Minority 
voted to end this inquiry and against releasing any additional 
documents.
    The Committee is not a law enforcement body. The Majority 
continues to be misguided about the authority of the Committee. 
The United States Supreme Court in the Committee's case 
regarding the IRS mandatory audit program stated, ``Congress 
cannot exercise its investigative powers for the purpose of law 
enforcement because the power of law enforcement is vested in 
the executive and judicial branches.'' This Committee is not a 
law enforcement body. It is a legislative body. The Committee 
has no independent power to enforce the tax laws against a 
private citizen and therefore no legislative purpose justifying 
this political fishing expedition. These matters are being 
handled by the courts.
    The additional documents failed to reveal any evidence of 
wrongdoing or political interference by President Biden. Once 
again, the Majority released additional documents provided by 
the whistleblowers. These documents contained zero evidence of 
political interference or wrongdoing by President Biden or his 
Administration. Not one single document directly or indirectly 
implicated President Biden of political interference.
    Most of the documents submitted to the Committee were 
previously summarized by one of the whistleblowers and released 
to the public last year. In 2023, one whistleblower submitted a 
summary (Exhibit 300) of text messages and WhatsApp messages 
that he believed were relevant to the IRS investigation. In the 
September 2023 executive session, the Committee released 
Exhibit 300 to the public. In this executive session, the 
Majority voted to release Exhibits 801 and 802, which are 
merely the underlying messages already summarized in Exhibit 
300.
    The Central Intelligence Agency (CIA) publicly denied the 
whistleblowers' allegations that the CIA blocked their ability 
to interview a witness in the IRS investigation. The 
whistleblowers submitted documents claiming that the CIA 
blocked their ability to interview a witness in the IRS 
investigation. However, the CIA responded in a letter dated 
April 4, 2024, that ``[t]he allegation is false.'' The letter 
also stated that ``the CIA did not prevent or seek to prevent 
the IRS or DOJ from interviewing a witness.'' The Majority does 
not let the facts get in the way.
    The Committee is unable to identify who requested these 
documents from the whistleblowers despite statements in the 
affidavits. The incoming affidavits from one whistleblower 
states that he provided the documents to the Committee ``as 
requested by staff with the relevant U.S. House Committees.'' 
During the markup, the Minority was told that neither Majority 
Committee staff nor Chairman Smith requested such documents. 
The Democratic staff also did not request these documents. 
Thus, the question remains as to who requested the documents.
    This is a stunning abuse of power by the Majority. The 
stunning abuse of the Committee's power in this instance 
demeans the stature of the Committee and reeks of partisanship. 
The Biden Administration has led the U.S. economy through the 
strongest and most successful post-pandemic recovery of any 
peer nation around the world. The jurisdiction of this 
Committee offers the Majority an enormous opportunity to 
improve the lives of the American people and build on our 
nation's economic successes. It is time for this Committee to 
get back to work for the American people and stop its pursuit 
of one private citizen.

                                           Richard E. Neal,
                                                    Ranking Member.
                              ----------                              

    Let me start off by sending our well wishes to our own Dr. 
Murphy, praying that his surgery is a success, and that he's 
back on this dais in no time. In the meantime, we will be 
keeping him in our prayers, and in our thoughts, along with his 
family. He is a part of the Ways and Means family. I want to 
wish Sean Clerget today a happy anniversary. It is his fifth 
year, I believe. And, Sean, I want to tell you. It is likely 
the last thing we are going to agree on this morning.
    To the topic at hand, you know how I feel about this and 
for details to emerge from the press last night demeans this 
Committee. It is the most serious matter that our Committee is 
entrusted with, and it is another stain on this work. 
Republicans have embraced a sham impeachment inquiry. It ought 
to be over, and everyone knows it, including many Members of 
the Republican Conference. Conservative pundits and allies 
alike have agreed that this inquiry is at a ``dead end,'' that 
it is ``falling flat,'' which has unveiled ``zero evidence of 
high crimes and misdemeanors.''
    After months of wasting time and thousands of taxpayer 
dollars, Republicans have convened yet another executive 
session. There is no legislative purpose to any of this. No 
dots have been connected, nothing new has been unveiled, and 
the Committee still hasn't been transformed into a law 
enforcement entity. You haven't succeeded in even embarrassing 
the President. And, by the way, nobody at home is talking about 
impeaching Joe Biden. This endeavor has showed just how far the 
Majority will go in pursuit of political gain by weaponizing 
the power of this Committee. As Jerry Seinfeld would have said, 
it is all about nothing.
    We are in the fourth executive session, and we anticipate 
it will be the final. The Majority has already lost the plot 
line, and the Committee's involvement should come to an end. 
The incoming affidavits from the whistleblowers state that the 
documents that were provided to the Committee ``as requested by 
staff [of the] relevant U.S. Committees.'' Let me point out, 
for the record, my staff certainly did not request these 
documents. For the life of me, we cannot understand the purpose 
that the Majority was imagining and why we would come again to 
this moment.
    Their obsession with one private citizen who has never held 
public office is wrong. And it is not within the longstanding 
tradition and norms of this, the most prestigious, Committee in 
Congress. The Committee has wasted countless hours on a fishing 
expedition, going absolutely nowhere fast.
    The Majority has reached a dead end. It is time to 
recognize that. Our colleagues on the other side of the aisle, 
I hope, recognize this morning's effort make no sense and we 
should get back to the work that we were elected to do.

                                                   Richard E. Neal.

                             V. ATTACHMENTS


A. Committee on Ways and Means Executive Session Markup Transcript, May 
        22, 2024

B. Joseph Ziegler's Affidavit 8

C. Exhibit 801, Chat 30: WhatsApp Message Chat between Hunter Biden and 
        James Biden.

D. Exhibit 801, Chat 41: WhatsApp Message Chat between Hunter Biden, 
        Mervyn Yan, Kevin Dong, Jackie, and James Biden.

E. Exhibit 801, Chat 59: WhatsApp Message Chat between Hunter Biden and 
        Kevin Dong.

F. Exhibit 801, Chat 60: WhatsApp Message Chat between Hunter Biden and 
        Kevin Dong.

G. Exhibit 801, Chat 61: WhatsApp Message Chat between Hunter Biden and 
        Vuk Jeremic.

H. Exhibit 801, Chat 62: WhatsApp Message Chat between Hunter Biden and 
        Raymond Zhao.

I. Exhibit 801, Chat 67: WhatsApp Message Chat between Hunter Biden and 
        Rob Walker.

J. Exhibit 801, Chat 70: WhatsApp Message Chat between Hunter Biden, 
        James Gilliar, Rob Walker, and James Biden.

K. Exhibit 802, Chat 3: WeChat Message Chat between Hunter Biden, Liu 
        Yadong, and Kelly.

L. Exhibit 802, Chat 7: WeChat Message Chat between Hunter Biden and 
        Devon Archer.

M. Exhibit 802, Chat 17: WeChat Message Chat between Hunter Biden, 
        James Biden, and Joe Biden.

N. Joseph Ziegler's Affidavit 9

O. Exhibit 901: May 14-15, 2014, Email from Hunter Biden to Vadim 
        Pozharskyi, cc'ing Sebastian Momtazi and Devon Archer, re: 
        Hunter Biden's Monthly Burisma Fee Expenses.

P. Exhibit 902: April 29, 2014, Email from Katie Dodge to Ralph 
        Krakhmal, re: Signed Rosemont Seneca Bohai LLC Corporate 
        Resolution.

Q. Exhibit 903: IRS CI Memorandum of Interview for Kathleen Buhle.

R. Exhibit 904: July 15-26, 2014, Emails Between Hunter Biden and James 
        Ursomarso, re: Porsche Transaction with Novatus and Rosemont 
        Seneca Bohai.

S. Exhibit 905: September 3-6, 2016, Emails Between Joan Mayer and 
        Lourdes Dominguez, cc'ing Eric Schwerin, Subject: Owasco, PC.

T. Exhibit 906: October 6, 2015, Emails Between Eric Schwerin and Devon 
        Archer, cc'ing Hunter Biden, re: CEFC China Energy 
        Introductions.

U. Exhibit 907: October 6, 2015, Email from Hunter Biden to Eric 
        Schwerin, Forwarding Email from glo hawk to Hunter Biden, 
        Subject: China.

V. Exhibit 908: December 10, 2015, Email from Eric Schwerin to Joan 
        Mayer, re: Email from Joan Mayer to Chairman Ye.

W. Exhibit 909: April 13, 2014, Email from Hunter Biden to Devon 
        Archer, re: Upcoming Travels.

X. Exhibit 910: April 17, 2014, Email from Devon Archer to Hunter 
        Biden, Forwarding Email from Vadim Pozharskyi to Devon Archer, 
        Subject: Follow Up Ideas.

Y. Exhibit 911: April 15, 2014, Emails Between Joan Peugh and Jamie 
        Lyons, re: Visit to White House.

Z. Exhibit 912: April 16, 2014, Event Email From Joan Peugh to Eric 
        Schwerin and Hunter Biden, White House Calendar Notification, 
        Subject: RHB: Meet Devon and Luke at WH.

AA. Exhibit 913: May 12, 2014, Email From Vadim Pozharskyi to Hunter 
        Biden, cc'ing Devon Archer, Subject: Urgent Issue, Attachments: 
        Criminal Code art 191, Inquiry to Geological Survey of Ukr, 
        Kroll report Zlochevskyi, Inquiry to State Geological Survey 
        English, Inquiry to Ministry of Ecology English, Inquiry to 
        Ministry of Ecology and Natural Resource.

BB. Exhibit 914: February 5, 2015, Email from Vadim Pozharskyi to 
        Hunter Biden, Robert Biden, and Devon Archer, cc'ing Alex 
        Kotlarsky, Subject: Mexico Trip, Nikolay.

CC. Exhibit 915: February 3, 2015, Email from Eric Schwerin to Hunter 
        Biden, Subject: Talked to Sandweg.

DD. Exhibit 916: May 6, 2016, Emails Between James Gilliar and Eric 
        Schwerin, cc'ing Rob Walker, Subject: Emails for Scheduling 
        Request.

EE. Joseph Ziegler's Affidavit 10

FF. Gary Shapley's Supplemental Affidavit

GG. Shapley Exhibit: Emails between Gary Shapley, Lesley Wolf, Jack 
        Morgan, Matthew McKenzie and Mark Daly, re: Gary Shapley's 
        request for a classified briefing on the information that the 
        CIA had provided to Lesley Wolf and Jack Morgan.

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