Taxpayer Due Process Enhancement Act suspends limitations on filing claims during IRS collection proceedings, prohibits crediting overpayments.
The Taxpayer Due Process Enhancement Act amends the Internal Revenue Code to suspend the period of limitations on filing a claim for credit or refund during IRS collection action proceedings. It also prohibits the crediting of overpayments against disputed tax liabilities during such proceedings, except with the taxpayer's consent. Additionally, the bill expands the jurisdiction of the Tax Court to include review of underlying tax liabilities properly disputed at hearings.
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