(a) In general

Subtitle D of the Internal Revenue Code of 1986 is amended by adding at the end the following new chapter:

50B Qualified settlement fund payments

5000E. Imposition of tax on qualified settlement fund payments

(a) In general

There is hereby imposed on any taxpayer for any taxable year a tax equal to 100 percent of any qualified settlement fund payment received by such taxpayer during such taxable year.

(b) Qualified settlement fund payment

For purposes of this section, the term qualified settlement fund payment means, with respect to any taxpayer for any taxable year, any amount received by such taxpayer during such taxable year from any fund established as a result of a civil action filed by the President of the United States against the Internal Revenue Service.

(c) Special rules

(1) Administrative provisions

For purposes of subtitle F, any tax imposed by this section shall be treated as a tax imposed by subtitle A.

(2) Exclusion from gross income

For purposes of chapter 1, the gross income of any taxpayer for any taxable year shall not include any qualified settlement fund payment received by such taxpayer during such taxable year.

(b) No deduction from income tax

Section 275(a)(6) of such Code is amended by inserting 50B, after 50A,.

(c) Clerical amendment

The table of chapters for subtitle D of such Code is amended by inserting after the item relating to chapter 50A the following new item:

(d) Effective date

The amendments made by this section shall apply with respect to amounts received after the date of the enactment of this Act.