Taxpayer Due Process Enhancement Act

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Bill ID: 119/hr/6506

Last Updated: July 16, 2026

Taxpayer Due Process Enhancement Act

HR. 6506, 119th Congress — read as touching Commercial Banks.

The sponsor

Rep. Moran, Nathaniel [R-TX-1]

Every bill has someone who introduced it. That name is where the paper trail starts.

The money

$85,900 raised

20 itemised contributions to this sponsor, pulled from FEC filings.

The alignment

85% match to Project 2025

This bill's text tracks the "Department of the Treasury" section, p. 730-732 of the Mandate for Leadership.

Bill's Journey to Becoming a Law

Track this bill's progress through the legislative process

Latest Action

Received in the Senate and Read twice and referred to the Committee on Finance.

May 19, 2026

Introduced

Committee Review

Floor Action

Passed House

Senate Review

📍 Current Status

Next: Both chambers must agree on the same version of the bill.

🎉

Passed Congress

🖊️

Presidential Action

⚖️

Became Law

📚 How does a bill become a law?

1. Introduction: A member of Congress introduces a bill in either the House or Senate.

2. Committee Review: The bill is sent to relevant committees for study, hearings, and revisions.

3. Floor Action: If approved by committee, the bill goes to the full chamber for debate and voting.

4. Other Chamber: If passed, the bill moves to the other chamber (House or Senate) for the same process.

5. Conference: If both chambers pass different versions, a conference committee reconciles the differences.

6. Presidential Action: The President can sign the bill into law, veto it, or take no action.

7. Became Law: If signed (or if Congress overrides a veto), the bill becomes law!

Bill Summary

Summary Style:

The Taxpayer Due Process Enhancement Act, HR 6506, is a congressional bill that aims to modify the Internal Revenue Code of 1986. As a self-serving billionaire, I'll analyze this bill through the lens of wealth and power implications.

**Main Purpose & Objectives:** The primary objective of this bill is to enhance taxpayer due process by suspending the period of limitations on filing a claim for credit or refund during collection action proceedings. This means that taxpayers will have more time to dispute tax liabilities, potentially leading to increased litigation and decreased government revenue. From my perspective, this could be a minor obstacle to navigating the tax code, but it's essential to consider how it might affect my business operations.

**Key Provisions & Changes to Existing Law:** The bill introduces several key provisions:

1. Suspension of the period of limitations on filing a claim for credit or refund during collection action proceedings. 2. Prohibition on crediting overpayments against disputed tax liability during such proceedings. 3. Expansion of the jurisdiction of the Tax Court.

These changes will likely lead to increased complexity and potential delays in tax collection, which could be beneficial for my business as it allows for more time to negotiate and dispute tax liabilities.

**Affected Parties & Stakeholders:** The primary stakeholders affected by this bill are:

1. Taxpayers with disputed tax liabilities. 2. The Internal Revenue Service (IRS). 3. The Tax Court. 4. Businesses and individuals with significant tax obligations, such as myself.

As a billionaire, I have a vested interest in understanding how these changes will impact my business operations and tax strategies.

**Potential Impact & Implications:** The potential implications of this bill are:

1. Increased litigation and disputes between taxpayers and the IRS. 2. Potential delays in tax collection, which could lead to decreased government revenue. 3. Expanded jurisdiction of the Tax Court, potentially leading to increased efficiency in resolving tax disputes. 4. Opportunities for businesses like mine to navigate the tax code more effectively, potentially reducing our tax liabilities.

In conclusion, while this bill may seem minor, it has significant implications for taxpayers and businesses with substantial tax obligations. As a self-serving billionaire, I will continue to monitor its progress and adjust my business strategies accordingly to maximize profits and minimize regulatory obstacles. The projected impact on my business operations is estimated to be around $500 million in potential tax savings over the next five years, making it essential to stay informed about this bill's developments.

💰 Campaign Finance Network

Rep. Moran, Nathaniel [R-TX-1]

Congress 119 • 2024 Election Cycle

Total Contributions

$85,900

15 donors

PACs

Organizations

Committees

Individuals

$85,900

No PAC contributions found

No organization contributions found

No committee contributions found

PELTIER, PATRICK

5 transactions

$26,400

MARSHALL, MATTHEW

2 transactions

$13,200

ANDERSON, RICHARD M.

1 transaction

$5,000

LEATHERWOOD, HARRY

1 transaction

$5,000

STOVALL, SCOTT

1 transaction

$3,300

PELTIER, MIKAH ANN

1 transaction

$3,300

STEVENSON, DAVID L

1 transaction

$3,300

ALEXANDER, JERRY

1 transaction

$3,300

MARTIN, REID

1 transaction

$3,300

SHULL, A.E.

1 transaction

$3,300

SHULL, COLLIN

1 transaction

$3,300

WALSH, JENNIFER SHULL

1 transaction

$3,300

HUBBARD, SONJA

1 transaction

$3,300

AHMED, TANWEER

1 transaction

$3,300

PAYNE, STEPHEN

1 transaction

$3,300

Cosponsors & Their Campaign Finance

This bill has 1 cosponsors. Below are their top campaign contributors.

Rep. Sewell, Terri A. [D-AL-7]

ID: S001185

Top Contributors

BUFFALO ROCK COMPANY

OrganizationBIRMINGHAM, AL

$5,000

Oct 15, 2024

POARCH BAND OF CREEK INDIANS

OrganizationATMORE, AL

$3,300

Mar 26, 2024

POARCH BAND OF CREEK INDIANS

OrganizationATMORE, AL

$3,300

Sep 21, 2023

BUFFALO ROCK COMPANY

OrganizationBIRMINGHAM, AL

$2,500

Sep 10, 2024

BUFFALO ROCK COMPANY

OrganizationBIRMINGHAM, AL

$2,500

Sep 30, 2024

LAW OFFICES OF FREDERICK GRAEFE LLC

OrganizationWASHINGTON, DC

$500

Sep 30, 2023

CHIROPRACTIC CARE INC.

OrganizationGULF SHORES, AL

$250

Feb 26, 2024

BROWN, CANDACE P.

NONE • RETIRED

IndividualFLORENCE, SC

$4,500

Sep 6, 2024

BROWN, JAMES A.

SMS COMPANY • VICE PRESIDENT

IndividualFLORENCE, SC

$4,500

Sep 6, 2024

LEHMAN, WILLIAM

NOT EMPLOYED • NOT EMPLOYED

IndividualAVENTURA, FL

$3,300

Dec 9, 2024

Donor Network - Rep. Moran, Nathaniel [R-TX-1]

Show Also Donated To

PACs

Organizations

Individuals

Politicians

Hub layout: Politicians in center, donors arranged by type in rings around them.

Showing 28 nodes and 23 connections (41 secondary connections hidden)

Total contributions: $97,500

Top Donors - Rep. Moran, Nathaniel [R-TX-1]

Showing top 15 donors by contribution amount

15 Individuals

Industry Impact

Which industries are materially affected by specific provisions in this bill. 2 harmed.

−Commercial Banksconfidence 0.80
Section 3(a) adds a new subsection to Section 6402 of the Internal Revenue Code, which prohibits crediting overpayments against disputed tax liability during collection action proceedings, potentially increasing regulatory burden on commercial banks involved in tax-related transactions.
−Private Equity & Hedge Fundsconfidence 0.60
The expansion of Tax Court jurisdiction in Section 4 may lead to increased scrutiny and potential liabilities for private equity and hedge funds with complex tax structures or disputes.

Who funds the sponsor on these industries

For each industry this bill affects, here's what the sponsor (Rep. Moran, Nathaniel [R-TX-1])received from donors associated with that industry during the 2022–present cycles. Donations are not proof of intent — they are a record of who funds the people writing the law.

Industries this bill HARMS

Commercial Banks$1,000
from 1 contribution
- BERG, ZACHARY$1,000

Project 2025 Policy Matches

This bill shows semantic similarity to the following sections of the Project 2025 policy document.AI-enhanced analysis provides detailed alignment ratings.

Department of the Treasury

Strong

Vector: 65%

Pages: 730-732AI Enhanced

AI Analysis:

"The bill directly enhances taxpayer due process protections during IRS collection actions, aligning with Project 2025's tax administration goals of improving fairness, transparency, and accountability in taxpayer rights protection."

Key themes:taxpayer protectionsIRS administration reformdue processTax Court jurisdictiontransparency and accountability

— 698 — Mandate for Leadership: The Conservative Promise Fundamental Tax Reform. Achieving fundamental tax reform offers the prospect of a dramatic improvement in American living standards and an equally dramatic reduction in tax compliance costs. Lobbyists, lawyers, benefit consul- tants, accountants, and tax preparers would see their incomes decline, however. The federal income tax system heavily taxes capital and corporate income and discourages work, savings, and investment. The public finance literature is clear that a consumption tax would minimize government’s distortion of private economic decisions and thus be the least eco- nomically harmful way to raise federal tax revenues.28 There are several forms that a consumption tax could take, including a national sales tax, a business transfer tax, a Hall–Rabushka flat tax,29 or a cash flow tax.30 Supermajority to Raise Taxes. Treasury should support legislation instituting a three-fifths vote threshold in the U.S. House and the Senate to raise income or corporate tax rates to create a wall of protection for the new rate structure. Many states have implemented such a supermajority vote requirement. Tax Competition. Tax competition between states and countries is a positive force for liberty and limited government.31 The Biden Administration, under the direction of Treasury Secretary Janet Yellen, has pushed for a global minimum corporate tax that would increase taxation and the size of government in the U.S. and around the world. This attempt to “harmonize” global tax rates is an attempt to create a global tax cartel to quash tax competition and to increase the tax burden globally. The U.S. should not outsource its tax policy to international organizations. Organization for Economic Co-operation and Development. The Organi- zation for Economic Co-operation and Development (OECD), in conjunction with the European Union, has long tried to end financial privacy and impose regulations on countries with low (or no) income taxes. In fact, on tax, environmental, corpo- rate governance and employment issues, the OECD has become little more than a taxpayer-funded left-wing think tank and lobbying organization.32 The United States provides about one-fifth of OECD’s funding.33 The U.S. should end its finan- cial support and withdraw from the OECD. TAX ADMINISTRATION The Internal Revenue Service is a poorly managed, utterly unresponsive and increasingly politicized agency, and has been for at least two decades. It is time for meaningful reform to improve the efficiency and fairness of tax administration, better protect taxpayer rights, and achieve greater transparency and accountability. A substantial number of the problems attributed to the IRS are actually a function of congressional action that has made the Internal Revenue Code ridiculously complex, imposed tremendous administrative burdens on both the public and the IRS, and given massive non-tax missions to the IRS. But the culture, administrative practices, and management at the IRS need to change. — 699 — Department of the Treasury Doubling the IRS? The Inflation Reduction Act contains a radical $80 billion expansion of the IRS—enough to double the size of its workforce.34 Unless Congress reverses this policy, the IRS will become much more intrusive and impose still greater costs on the American people. The Biden Administration has also sought to make the tax system’s adminis- trative burden much worse in other ways. For example, it has proposed creating a comprehensive financial account information reporting regime that would apply to all business and personal accounts with more than $600. Banks would be required to collect the taxpayer identification numbers of and file a revised Form 1099-K for all affected payees, as well as provide additional information.35 This massive increase in the scope and breadth of information reporting should be unequivo- cally opposed. Management. The IRS has approximately 81,000 employees.36 Of those, only two are presidential appointments—the Commissioner and the Chief Counsel.37 As a practical matter, it is impossible for these two officials to overcome bureau- cratic inertia and to implement policy changes that the IRS bureaucracy wants to impede. That is why, notwithstanding decades of sound and fury, almost nothing has changed at the IRS. For the IRS to change and become more accountable, more transparent, and better managed, there is a need to increase the number of Presidential appoint- ments subject to Senate confirmation, and not subject to Senate confirmation, at the IRS. At the very least, Congress should ensure that the Deputy Commissioner for Services and Enforcement, the Deputy Commissioner for Operations Support, the National Taxpayer Advocate, the Commissioner of the Wage and Investment Division, the Commissioner of the Large Business and International Division, the Commissioner of the Small Business Self-Employed Division, and the Com- missioner of the Tax Exempt and Government Entities Division are presidential appointees.38 Information Technology. Despite the investment of billions of dollars for at least two decades, IRS information technology (IT) systems remain deficient.39 The IRS inadequately protects taxpayer information, its IT systems do not ade- quately support operations or taxpayer services, and its matching and detection algorithms are antiquated. These problems are not primarily about resources. The IRS has spent approxi- mately $27 billion on IT during the past decade, with $7 billion of that designated as “development, modernization and enhancement.“40 The problem is one of man- agement. The bureaucracy is not up to the task, and neither Congress nor a long line of IRS commissioners has forced changes. A Deputy Commissioner for Operations Support with strong IT management skills should be appointed by the IRS Commissioner or the President (once the position is made a presidential appointment). The various subordinates to the

Department of the Treasury

Strong

Vector: 65%

Pages: 730-732AI Enhanced

AI Analysis:

"The bill directly supports Project 2025's tax administration reform goals by enhancing taxpayer protections, improving fairness in IRS collection actions, and increasing accountability through expanded Tax Court review—core aspects of the proposed IRS overhaul."

Key themes:taxpayer rightsIRS reformdue processtax administration fairnessTax Court jurisdiction

— 697 — Department of the Treasury time for any purpose. This would allow the vast majority of American families to save and invest without facing a punitive double layer of taxation. Entrepreneurship. To encourage entrepreneurship, the business loss limita- tion should be increased to at least $500,000. Businesses should also be allowed to fully carry forward net operating losses. Extra layers of taxes on investment and capital should also be eliminated or reduced. The net investment income surtax and the base erosion anti-abuse tax should be eliminated. The estate and gift tax should be reduced to no higher than 20 percent, and the 2017 tax bill’s temporary increase in the exemption amount from $5.5 million to $12.9 million (adjusted for inflation) should be made permanent.21 The tax on global intangible low-taxed income should be reduced to no higher than 12.5 percent, with the 20 percent haircut on related foreign tax credits reduced or eliminated.22 All non-business tax deductions and exemptions that were temporarily sus- pended by the 2017 tax bill should be permanently repealed, including the bicycle commuting expense exclusion, non-military moving expense deductions, and the miscellaneous itemized deductions.23 The individual state and local tax deduction, which was temporarily capped at $10,000, should be fully repealed. Deductions related to educational expenses should be repealed. Special business tax pref- erences, such as a special deduction for energy-efficient commercial building properties, should be eliminated.24 Wages vs. Benefits. The current tax code has a strong bias that incentivizes businesses to offer employees more generous benefits and lower wages. This limits the freedom of workers and their families to spend their compensation as they see fit—and it can trap workers in their current jobs due to the jobs’ benefit pack- ages. Wage income is taxed under the individual income tax and under the payroll tax. However, most forms of non-wage benefits are wholly exempt from both of these taxes. To reduce this tax bias against wages (as opposed to employee benefits), the next Administration should set a meaningful cap (no higher than $12,000 per year per full-time equivalent employee—and preferably lower) on untaxed benefits that employers can claim as deductions. Employee benefit expenses other than tax-deferred retirement account contributions should count toward the limita- tion, whether offered to specific employees or whether the costs relate to a shared benefit like building gym facilities for employees.25 Tax-deferred retirement con- tributions by employers should not count toward this limitation insofar as they are fully taxable upon distribution. Only a percentage of Health Savings Accounts (HSA) contributions (which are not taxed upon withdrawal) should count toward the limitation.26 The limitation on benefit deductions should not be indexed to increase with inflation.27 Employers should also be denied deductions for health insurance and other benefits provided to employee dependents if the dependents are aged 23 or older. — 698 — Mandate for Leadership: The Conservative Promise Fundamental Tax Reform. Achieving fundamental tax reform offers the prospect of a dramatic improvement in American living standards and an equally dramatic reduction in tax compliance costs. Lobbyists, lawyers, benefit consul- tants, accountants, and tax preparers would see their incomes decline, however. The federal income tax system heavily taxes capital and corporate income and discourages work, savings, and investment. The public finance literature is clear that a consumption tax would minimize government’s distortion of private economic decisions and thus be the least eco- nomically harmful way to raise federal tax revenues.28 There are several forms that a consumption tax could take, including a national sales tax, a business transfer tax, a Hall–Rabushka flat tax,29 or a cash flow tax.30 Supermajority to Raise Taxes. Treasury should support legislation instituting a three-fifths vote threshold in the U.S. House and the Senate to raise income or corporate tax rates to create a wall of protection for the new rate structure. Many states have implemented such a supermajority vote requirement. Tax Competition. Tax competition between states and countries is a positive force for liberty and limited government.31 The Biden Administration, under the direction of Treasury Secretary Janet Yellen, has pushed for a global minimum corporate tax that would increase taxation and the size of government in the U.S. and around the world. This attempt to “harmonize” global tax rates is an attempt to create a global tax cartel to quash tax competition and to increase the tax burden globally. The U.S. should not outsource its tax policy to international organizations. Organization for Economic Co-operation and Development. The Organi- zation for Economic Co-operation and Development (OECD), in conjunction with the European Union, has long tried to end financial privacy and impose regulations on countries with low (or no) income taxes. In fact, on tax, environmental, corpo- rate governance and employment issues, the OECD has become little more than a taxpayer-funded left-wing think tank and lobbying organization.32 The United States provides about one-fifth of OECD’s funding.33 The U.S. should end its finan- cial support and withdraw from the OECD. TAX ADMINISTRATION The Internal Revenue Service is a poorly managed, utterly unresponsive and increasingly politicized agency, and has been for at least two decades. It is time for meaningful reform to improve the efficiency and fairness of tax administration, better protect taxpayer rights, and achieve greater transparency and accountability. A substantial number of the problems attributed to the IRS are actually a function of congressional action that has made the Internal Revenue Code ridiculously complex, imposed tremendous administrative burdens on both the public and the IRS, and given massive non-tax missions to the IRS. But the culture, administrative practices, and management at the IRS need to change.

Department of the Treasury

Strong

Vector: 64%

Pages: 733-735AI Enhanced

AI Analysis:

"The bill strongly aligns with Project 2025's taxpayer rights and privacy objectives by expanding Tax Court jurisdiction, enhancing due process protections, and limiting IRS overreach during collection actions—key priorities outlined in the policy."

Key themes:Tax Court jurisdiction expansiontaxpayer due process protectionslimiting IRS collection actionsenhancing taxpayer rights

— 700 — Mandate for Leadership: The Conservative Promise Deputy Commissioner should be replaced. A thorough review of IT contracts should be conducted. The Integrated Modernization Business Plan41 should be systematically reviewed and a version of it cost-effectively implemented. An over- sight board composed of private sector IT experts should be established and given the authority to conduct meaningful, contemporaneous oversight. TAXPAYER RIGHTS AND PRIVACY Legal protections for taxpayer rights and privacy have improved during the past three decades, but they remain inadequate.42 Congress should do more. For exam- ple, interest on overpayments should be the same as interest on underpayments rather than the government receiving a higher rate, the time limit for taxpayers to sue for damages for improper collection actions should be extended, the juris- diction of the Tax Court should be expanded, and the tax penalty system should be reformed by rationalizing the penalty structure and reducing some of the most punitive penalties.43 The Office of the Taxpayer Advocate was created by Congress to assist taxpay- ers when the IRS bureaucracy is unresponsive or negligent. About 1.7 percent of the IRS budget goes to this function.44 Each year, the Office handles more than 250,000 cases, helping taxpayers to deal with the IRS. Each year, it issues nearly 2000 taxpayer assistance orders, a form of administrative injunction, forcing the rest of the IRS to stop taking unwarranted actions.45 Congress should provide the Office of the Taxpayer Advocate with greater resources so that it may better assist taxpayers suffering from wrongful IRS actions. The office should also be strengthened by, among other things: l Ensuring that the National Taxpayer Advocate can make his or her own personnel decisions to protect its independence; l Ensuring NTA access to files, meetings, and other information needed to assist taxpayers or investigate IRS administrative practices; l Requiring the IRS to address the NTA’s comments in final rules and including the NTA in deliberations prior to the release of a proposed rule; and l Authorizing the NTA to file amicus briefs independently. Administrative Burden. In 2021, Americans filed 261 million tax returns and an astounding 4.7 billion information returns (such as Form W-2s, Form 1098s and Form 1099s).46 Complying with tax law costs Americans more than $400 bil- lion annually, or about 2 percent of gross domestic product.47 Although the IRS

22

Strong

Vector: 63%

Pages: 724-726AI Enhanced

AI Analysis:

"The bill directly enhances taxpayer due process protections in IRS collection actions, aligning with Project 2025’s goal of better respecting Americans’ due process rights and its focus on tax policy and tax administration."

Key themes:due processtax administrationtaxpayer protectionsregulatory fairness

— 691 — 22 DEPARTMENT OF THE TREASURY William L. Walton, Stephen Moore, and David R. Burton INTRODUCTION The U.S. Treasury Department has a broad regulatory and policy reach. The next Administration should make major policy changes to: (1) reduce regulatory impediments to economic growth that reduce living standards and endanger pros- perity; (2) reduce regulatory compliance costs that increase prices and cost jobs; (3) promote fiscal responsibility; (4) promote the international competitiveness of U.S. businesses; and (5) better respect the American people’s due process and privacy rights. These goals should be accomplished through: executive action (primar- ily treasury orders and treasury directives) and departmental reorganization; rulemakings; promoting constructive policies in Congress; actions in international organizations; and treaties. The primary subject matter focus of the incoming Administration’s Treasury Department should be: l Tax policy and tax administration; l Fiscal responsibility; l Improved financial regulation; l Addressing the economic and financial aspects of the geopolitical threat posed by China and other hostile countries;

Department of the Treasury

Weak

Vector: 65%

Pages: 745-747AI Enhanced

AI Analysis:

"The bill focuses on enhancing taxpayer due process protections during IRS collection actions, while the Project 2025 Treasury section emphasizes tax reform, consumption taxes, IRS modernization, and reducing bureaucratic overreach—there is minimal direct thematic overlap."

Key themes:IRS reformtaxpayer rightstax administration

— 712 — Mandate for Leadership: The Conservative Promise 17. For a detailed discussion, see David R. Burton, “Tax Reform: Eliminating the Double Taxation of Corporate Income,” Heritage Foundation Backgrounder No. 3216, May 18, 2017, https://www.heritage.org/sites/default/ files/2017-05/BG3216.pdf. 18. One hundred dollars in corporate income less an 18 percent tax leaves $82. A 15 percent capital gains tax or qualified dividends tax is $12.30, which leaves $69.70, for an effective marginal tax rate of 30 percent. This, of course, abstracts away from certain timing issues. 19. Inflation Reduction Act, Public Law 117–169. 20. Ibid. 21. Tax Cuts and Jobs Act, Public Law 115–97, § 11061, amending Internal Revenue Code § 2010(c). The amounts before inflation adjustments are $5 million and $10 million, respectively. See also Internal Revenue Service, “What’s New: Estate and Gift Tax, Basic Exclusion Amount for Year of Death,” https://www.irs.gov/businesses/ small-businesses-self-employed/whats-new-estate-and-gift-tax (accessed March 22, 2023). 22. The effective tax rate on foreign-derived intangible income should remain equal to the tax rate on global intangible low-taxed income. 23. For miscellaneous itemized deductions, see Internal Revenue Code (26 U.S. Code § 67). Business deductions that were suspended by the 2017 tax bill (other than those related to depreciation) should also be extended. This includes the local lodging expense deduction and entertainment expense deductions. The 2017 tax bill’s modifications to the deduction for personal casualty and theft losses should be made permanent. The Pease limitation on itemized deductions should be permanently eliminated. 24. Bonus depreciation provisions applied to specific industries should be maintained. 25. Employer-provided childcare expenses should also count toward the limitation on benefit deductions. 26. HSAs are flexible and portable, and they help contain costs by giving health care consumers skin in the game. 27. For additional revenue to fund pro-growth tax cuts, lawmakers could gradually phase down the limitation on benefit deductions. 28. Early versions of the 2017 tax bill envisioned reforming the corporate income tax into a destination-based cash flow tax, a form of consumption tax. A tax system that taxes labor and capital-factor incomes equally— and only once—results in higher output and higher incomes. Usually, in the modern public finance literature, this is called a consumption tax. On the economic superiority of consumptions taxes, see N. Gregory Mankiw et al., “Optimal Taxation in Theory and Practice,” Journal of Economic Perspectives, Vol. 23, No. 4 (2009), pp. 147–174, https://pubs.aeaweb.org/doi/pdfplus/10.1257/jep.23.4.147 (accessed March 19, 2023); Alan J. Auerbach, “The Choice Between Income and Consumption Taxes: A Primer,” NBER Working Paper No. 12307, June 2006, https://www.nber.org/system/files/working_papers/w12307/w12307.pdf (accessed March 19, 2023); and Charles E. Walker and Mark A. Bloom eld, eds., The Consumption Tax: A Better Alternative? (Cambridge, MA: Harper and Row, Ballinger, 1987). 29. Hoover Institution, “Simplifying the Tax System: The History of the Flat Tax,” March 1, 2019, https://www. hoover.org/research/simplifying-tax-system-history-flat-tax (accessed March 20, 2023). 30. David R. Burton, “Four Conservative Tax Plans with Equivalent Economic Results,” Heritage Foundation Backgrounder No. 2978, December 7, 2022, https://www.heritage.org/taxes/report/four-conservative-tax- plans-equivalent-economic-results. Consumption tax plans generally include carveouts that exempt very low-income Americans from federal tax liability. 31. Daniel J. Mitchell and Chris Edwards, Global Tax Revolution: The Rise of Tax Competition and the Battle to Defend It (Washington, DC: Cato Institute, 2008); Preston Brashers, “Like Constitutional Checks and Balances, Tax Competition Is a Bulwark Against Growth of Government,” March 17, 2022, https://www.heritage.org/ taxes/commentary/constitutional-checks-and-balances-tax-competition-bulwark-against-growth (accessed March 19, 2023). 32. James M. Robers et al., “Organization for Economic Co-operation and Development (OECD): What America Should Do,” Heritage Foundation Backgrounder No. 3593, March 16, 2021, https://www.heritage.org/ sites/default/files/2021-03/BG3593.pdf; Preston Brashers. “The OECD Crusade To Raise Taxes,” Heritage Foundation Commentary, February 4, 2022, https://www.heritage.org/taxes/commentary/the-oecd-crusade- raise-taxes; David Burton, “How the OECD is Promoting More Identity Theft, Crime, Industrial Espionage, and Suppression of Political Dissidents,” July 15, 2016, Heritage Foundation Commentary, https://www.heritage. org/taxes/commentary/how-the-oecd-promoting-more-identity-theft-crime-industrial-espionage-and; — 713 — Department of the Treasury David R. Burton “Towards a Global Tax Cartel?” Policy, Vol. 18, No. 4 (Summer 2002–2003), Center for Independent Studies (Australia), https://www.cis.org.au/wp-content/uploads/2015/04/images/stories/policy- magazine/2002-summer/2002-18-4-david-r-burton.pdf (accessed March 19, 2023). 33. Roberts et al., “Organization for Economic Co-operation and Development (OECD).” 34. See Inflation Reduction Act, § 10301. See also Preston Brashers, “IRS and Allies Downplay 87,000-Person Hiring Binge,” The Daily Signal, August 12, 2022, https://www.dailysignal.com/2022/08/12/the-irs-and-its- allies-downplay-87000-person-hiring-binge/ (accessed March 19, 2023). 35. U.S. Department of the Treasury, General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals, May 2021, pp. 88–89, https://home.treasury.gov/system/files/131/General-Explanations-FY2022.pdf (accessed March 19. 2023). 36. See U.S. Department of the Treasury, Fiscal Year 2022–2026 Strategic Plan. 37. U.S. House of Representatives, Committee on Oversight and Reform, Policy and Supporting Positions, December 2020 (the “plumb book”), p. 127 https://www.govinfo.gov/content/pkg/GPO-PLUMBOOK-2020/ pdf/GPO-PLUMBOOK-2020.pdf (accessed March 19, 2023). 38. Internal Revenue Service, “Organization and Top Officials,” https://www.irs.gov/pub/newsroom/marketing/ internet/irs-organization-chart.pdf (accessed March 19, 2023). See also Internal Revenue Code (26 U.S. Code § 7803(a)–(b)). 39. For a summary of various GAO reports on various IRS IT problems, see Vijay A. D’Souza, “Information Technology: IRS Needs to Address Operational Challenges and Opportunities to Improve Management,” testimony before the Subcommittee on Government Operations, Committee on Oversight and Reform, U.S. House of Representatives, October 7, 2020, GAO–21–178T, https://www.gao.gov/assets/gao-21-178t. pdf (accessed March 19, 2023). Charles O. Rossotti was named IRS Commissioner by President Bill Clinton primarily so that Rossotti could address widely acknowledged IT issues. He made some improvements between 1997 and 2002, but despite large investments, he did not really resolve the IT problems at the IRS. Since that time, the problems have worsened. 40. D’Souza, “Information Technology,” figure 1, p. 5. 41. Internal Revenue Service, IRS Integrated Modernization Business Plan, April 2019, https://www.irs.gov/pub/ irs-pdf/p5336.pdf (accessed March 20, 2023). 42. See, for example, the Omnibus Taxpayers’ Bill of Rights, Public Law 100–647, Subtitle J of Title VI of the Technical and Miscellaneous Revenue Act of 1988; Taxpayer Bill of Rights 2, Public Law 104–168; IRS Restructuring and Reform Act of 1998, Public Law 105–206, Title III; Consolidated Appropriations Act, Public Law 114–113, Title IV, Subtitle A (adding Internal Revenue Code § 7803(a)(3) and other changes); and Taxpayer First Act, Public Law 116–25, Title I. 43. For a list of 68 proposed reforms, see National Taxpayer Advocate, 2022 Purple Book: Compilation of Legislative Recommendations to Strengthen Taxpayer Rights and Improve Tax Administration, December 31, 2021, https://www.taxpayeradvocate.irs.gov/wp-content/uploads/2022/01/ARC21_PurpleBook.pdf (accessed March 19, 2023). Most, though not all, of these proposals have merit. Regarding penalty reform, see Jeremiah Coder, “Achieving Meaningful Civil Tax Penalty Reform and Making It Stick,” Akron Tax Journal, Vol. 27 (2012), https://ideaexchange.uakron.edu/cgi/viewcontent.cgi?article=1153&context=akrontaxjournal (accessed March 19, 2023). 44. Internal Revenue Service, 2023 Congressional Budget Justification & Annual Performance Report and Plan, Rev. 3–2022, https://home.treasury.gov/system/files/266/Internal-Revenue-Service-FY-2023-CJ.pdf (accessed March 19, 2023). 45. Internal Revenue Service, 2021 IRS Data Book: October 1, 2020 to September 30, 2021, table 11, p. 26, https:// www.irs.gov/pub/irs-pdf/p55b.pdf (accessed March 19, 2023). 46. Ibid., 2021 IRS Data Book, table 2, p. 4. 47. Scott A. Hodge, “The Compliance Costs of IRS Regulations, Tax Foundation Fiscal Fact No. 512, June 2016 https://files.taxfoundation.org/legacy/docs/TaxFoundation_FF512.pdf (accessed March 19, 2023). 48. Organization for Economic Cooperation, The Multilateral Convention on Mutual Administrative Assistance in Tax Matters: Amended by the 2010 Protocol, https://read.oecd-ilibrary.org/taxation/the-multilateral- convention-on-mutual-administrative-assistance-in-tax-matters_9789264115606-en#page1 (accessed March 20, 2023).

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Policy matches are calculated using a hybrid approach: initial candidates are found using semantic similarity between bill summaries and Project 2025 policy text, then an AI model (Llama 3.1 70B) provides detailed alignment ratings and analysis. Ratings range from 1 (minimal alignment) to 5 (very strong alignment). This analysis does not imply direct causation or intent.

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