Pauses the deadline for filing a tax refund claim while a taxpayer disputes an IRS collection action, bars the IRS from applying an overpayment against disputed tax debt during that dispute unless the taxpayer consents, and allows the Tax Court to review disputed underlying tax liabilities in collection cases.

• Suspends the deadline for claiming a credit or refund while a properly disputed collection hearing is pending, and ends the suspension once the taxpayer loses the dispute through a missed deadline, court filing, or court order.
• Prohibits crediting an overpayment against a disputed tax liability during collection proceedings unless the taxpayer agrees.
• Extends the rules for levy hearings to lien hearings by covering collection actions and proposed collection actions, not only levies.
• Lets a taxpayer petition the Tax Court within 30 days to review a collection determination and any disputed underlying tax liability, and keeps that jurisdiction even if the IRS drops the collection action. Applies to petitions filed after enactment.

• Ways and Means Committee (House)
• Finance Committee (Senate)

Taxation