(1)

may be filed by such person electronically, and

(2)

if such return or amendment is filed electronically, shall be processed electronically by the Secretary.

(1)

any return which is received by the Internal Revenue Service only in a paper form, or

(2)

any correspondence which is received by the Internal Revenue Service only in a paper form.

(1) In general

Subsection (b) shall not apply to any technology to the extent that the Secretary determines such technology is slower or less reliable than—

(2) Report to congress

Any exception to the application of a technology described in subsection (b) pursuant to paragraph (1) shall not take effect unless the Secretary provides a report to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate regarding the determination made by the Secretary under such paragraph within 30 days of such determination.

(1)

any individual income tax return (as defined in section 6011(e)(3)(C) of the Internal Revenue Code of 1986) received on or after January 1 of the first calendar year beginning more than 180 days after the date of enactment of this Act,

(2)

any estate tax return (as described in section 6018 of such Code) or gift tax return (as described in section 6019 of such Code) received on or after January 1 of the first calendar year beginning more than 24 months after the date of enactment of this Act, and

(3)

any other return or correspondence received on or after January 1 of the first calendar year beginning more than 18 months after the date of enactment of this Act.

(1)

Separately with respect to each applicable phone number extension—

(2)

An application or tool embedded on the website which—

(3)

An application programming interface which allows any person to access the information described in subsection (a)(1) using automation and to create an application or tool embedded on a website to display such information.

(4)

For each applicable phone number extension, a summary of the information described in paragraph (1) with respect to the prior month, including—

(1) Applicable item

The term applicable item means each category of tax return, claim, statement, or other document filed with the Internal Revenue Service.

(2) Applicable phone number extension

The term applicable phone number extension means any extension or application which may be reached by calling a phone number which is listed by the Internal Revenue Service on any website, publication, form, or instruction which is available to the public and—

(3) Significant delay

The term significant delay means, in the case of any applicable item for any week, the failure to process all of such applicable items which were received by the Internal Revenue Service at least 21 days before the first day of the week.

(A)

the date on which the Internal Revenue Service issued any refund of any overpayment of tax,

(B)

the estimated date on which the taxpayer can expect to receive such refund, and

(C)

(A)

the reason for the suspension, and

(B)

in the case of any information which was requested by the Internal Revenue Service—

(1)

in a manner consistent with any applicable limitations under section 6103 of the Internal Revenue Code of 1986, view any return (as defined in section 6103(b)(1) of the Internal Revenue Code of 1986), document, notice, or letter (with the exception of any educational item which has no legal effect) which, during the applicable period (as defined in subsection (d)), has been—

(2)

with respect to any document, notice, or letter sent to such taxpayer by the Internal Revenue Service, respond to such document, notice, or letter by uploading or otherwise transmitting the taxpayer's response through the website or mobile application, and

(3)

in the case of—

permit such representative, preparer, or agent, to the extent authorized by the taxpayer, to access the information described in paragraph (1) or transmit any information described in paragraph (2).

(1) In general

Subject to paragraph (2), for purposes of subsection (a)(1), the term applicable period means the preceding 6-year period.

(2) Prospective application

The term applicable period shall not include any years ending before the date of enactment of this Act.

(1) In general

For purposes of this section, the term qualified reporting agent means a person—

(2) Employment tax return

For purposes of paragraph (1)(A), the term employment tax return means—

(1)

establish a program to investigate and address—

(2)

annually publish, on the public website of the Internal Revenue Service, the actions undertaken pursuant to the program described in paragraph (1), such as the number of complaints investigated, the number of persons whose access was revoked, and other relevant statistical data.

(1)

by striking In the case and inserting the following:

(1) Authority

Except as provided in paragraph (2), in the case, and

(2)

by adding at the end the following new paragraphs:

(2) Special rule for certain individuals

In the case of an overpayment with respect to any taxable year for which a credit is allowed to an applicable taxpayer under section 32, the Secretary shall, subject to subsections (c), (d), (e), and (f), refund such overpayment in an amount not to exceed the amount of the credit allowed under such section for such taxable year.

(3) Applicable taxpayer

For purposes of paragraph (2), the term applicable taxpayer means a taxpayer who was classified by the Secretary as currently not collectible (within the meaning of section 6343(e)) prior to the date on which the refund was requested by the taxpayer.

(1)

establish a program to identify taxpayers who—

(2)

in the case of any taxpayer described in paragraph (1) who requests to enter into an agreement described in section 6159(a) of the Internal Revenue Code of 1986, provide such taxpayer with information regarding other options which the Internal Revenue Service makes available to taxpayers who have an unpaid tax liability and are experiencing an economic hardship, including—

(1)

the most recent income and asset data which the Secretary has received from a return or a report from, or with respect to, such taxpayer, and

(2)

the schedules described in section 7122(d)(2)(A) of such Code.

(1)

the accuracy of the Internal Revenue Service with respect to identifying taxpayers who are reasonably likely to be experiencing an economic hardship under subsection (a)(1),

(2)

whether such identification procedures may be appropriately applied for other purposes, and

(3)

(1)

in the heading, by striking Annual notice and inserting Notice,

(2)

by striking Not less often than annually and inserting the following:

(a) In general

Except as provided in subsection (b), not less often than quarterly, and

(3)

by adding at the end the following:

(b) Information on penalties and interest

The notice described in subsection (a) shall include—

(1)

an estimate of the amount of penalties and interest that may accrue if the delinquent tax debt is not fully paid within the period remaining under section 6502(a), and

(2)

programs and services that can provide assistance to the taxpayer.

(c) Exception

The requirement under subsection (a) shall not apply—

(1)

during any period in which an agreement described in section 6159(a) or an accepted offer-in-compromise (as described in section 7122) is in effect, or

(2)

in the case of a taxpayer for which the Secretary has determined that the tax is not collectible (within the meaning of section 6343(e)).

(1)

by striking paragraphs (1) and (2), and

(2)

by redesignating paragraphs (3) through (6) as paragraphs (1) through (4).

(1)

by striking paragraph (1) and inserting the following:

(1) In general

No penalty under this title shall be assessed, and no disallowance period shall take effect, unless—

(A)

the decision (as defined by the Secretary in regulations) to apply such penalty or disallowance period, as applicable, is personally approved (in writing on an electronic form) by—

(i)

the immediate supervisor of the individual making such decision, or

(ii)

the Internal Revenue Service Office of Servicewide Penalties (or any successor organization), and

(B)

the approval described in subparagraph (A) is obtained on or before the date any appealable notice is sent to the taxpayer regarding the application of such penalty or disallowance period., and

(2)

by adding at the end the following:

(3) Appealable notice

For purposes of this subsection, the term appealable notice means the first written notice issued to a taxpayer that provides the taxpayer an opportunity to—

(A)

appeal the decision to the Internal Revenue Service Independent Office of Appeals, or

(B)

petition a Federal court for review of the decision.

(1)

every organizational unit of the Internal Revenue Service that has power to assess, abate, or otherwise enforce any penalty imposed by the Internal Revenue Service under the Internal Revenue Code of 1986, and

(2)

the progression of such penalties at each step of the determination, assessment, and review processes, as well as the final result with respect to such penalties.

(1)

in subsection (a)(1)—

(2)

in subsection (d)(2)—

(1)

an analysis of successes and challenges with respect to implementation of such title, and

(2)

any recommendations to Congress with respect to the implementation or administration of such title.

(1) In general

Not later than the date which is 12 months after the date of enactment of this Act, and annually thereafter, the Secretary shall provide a report to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate regarding efforts made by the Internal Revenue Service to identify, prevent, and resolve each type of tax fraud, including first-person fraud and stolen identity refund fraud.

(2) Information included in report

The report described in paragraph (1) shall include—

(3) Publicly available

Data included in the report described in paragraph (1) shall be made available on the public website of the Internal Revenue Service, provided that such data is appropriately redacted by the Secretary.

(1) In general

The Secretary of the Treasury (or the Secretary's delegate) shall conduct a study on—

(2) Consultation

The study conducted under paragraph (1) shall include input from the National Taxpayer Advocate and nonresident United States taxpayers.

(1) In general

The Comptroller General of the United States shall conduct a study on the burdens of compliance with Federal tax laws applicable to individuals who are United States persons (as defined in section 7701(a)(30) of the Internal Revenue Code of 1986) living abroad.

(2) Factors considered

The study conducted under subsection (a) shall identify problems relating to compliance of Federal tax laws for such United States persons, including burdens specific to low-income and moderate-income individuals, related to—

(3) Report

Not later than 1 year after the date of the enactment of this Act, the Comptroller General shall submit to the Secretary of the Treasury and to Congress, and make publicly available, a report on the study conducted under paragraph (1).

(1)

actions taken by the Department of the Treasury to address any problems identified by the Comptroller General in such report; and

(2)

any legislation necessary to address such problems.

(1) In general

The second sentence of section 988(e)(2) is amended by striking $200 and inserting $1,000.

(2) Inflation adjustment

Section 988(e) is amended by adding at the end the following new paragraph:

(4) Inflation adjustment

(A) In general

In the case of any taxable year beginning after 2025, the $1,000 amount in paragraph (2) shall be increased by an amount equal to—

(i)

such dollar amount, multiplied by

(ii)

the cost-of-living adjustment determined under section 1(f)(3) for the calendar year in which the taxable year begins, determined by substituting in subparagraph (A)(ii) thereof calendar year 2024 for calendar year 2016.

(B) Rounding

If any amount as adjusted under subparagraph (A) is not a multiple of $50, such dollar amount shall be rounded to the next lowest multiple of $50.

(1) In general

Section 165(c) is amended by striking and at the end of paragraph (2), by striking the period at the end of paragraph (3) and inserting a comma, and by adding at the end the following new paragraphs:

(4)

foreign currency losses not described in paragraph (1) or (2) with respect to qualified mortgage debt, but only to the extent of any gain recognized during the taxable year on the sale of a qualified residence (as defined in section 163(h)(5)) which is located outside of the United States or any possession of the United States and which secures such qualified mortgage debt, and

(5)

losses (not described in paragraph (1) or (2)) from the sale or exchange of a qualified residence (as so defined) which is located outside of the United States or any possession of the United States, but only to the extent of any foreign currency gain recognized during the taxable year with respect to qualified mortgage debt secured by such qualified residence.

(2) Qualified mortgage debt

Section 165 is amended by redesignating subsection (m) as subsection (n) and by inserting after subsection (l) the following new subsection:

(m) Definitions related to qualified mortgage debt and foreign currency gains and losses

For purposes of this section—

(1) Qualified mortgage debt

The term qualified mortgage debt means—

(A)

any acquisition indebtedness (as defined in section 163(h)(3)(B), determined without regard to clause (ii) thereof) of an individual,

(B)

any home equity indebtedness (as defined in section 163(h)(3)(C), determined without regard to clause (ii) thereof) of an individual, and

(C)

any other indebtedness (including any non-debt that functions as debt) which is related to the purchase or ownership of real estate by, or for the benefit of, individuals and which is approved under regulations or guidance provided by the Secretary.

(2) Foreign currency loss

The term foreign currency loss means, with respect to any qualified mortgage debt, any loss which would be described in section 988(b)(2) if the transaction involving the qualified mortgage debt were treated as a section 988 transaction.

(3) Foreign currency gain

The term foreign currency gain means, with respect to any qualified mortgage debt, any gain which would be described in section 988(b)(1) if the transaction involving the qualified mortgage debt were treated as a section 988 transaction.

(3) Character and source of loss

Section 165(f) is amended to read as follows:

(4) Treatment of foreign currency loss deduction

Section 62(a) is amended by inserting after paragraph (21) the following new paragraph:

(22) Certain foreign currency losses

The deduction allowed by section 165(c)(4).

(1) In general

Section 6212(a) is amended—

(2) Effective date

The amendments made by this subsection shall apply to notices mailed 36 months after the date of enactment of this Act.

(1) In general

Section 6214 is amended by redesignating subsection (e) as subsection (f) and by inserting after subsection (d) the following new subsection:

(e) Jurisdiction with respect to multi-Year bans with respect to certain credits

(1) In general

The Tax Court shall have jurisdiction—

(A)

to redetermine the imposition of any disallowance period with respect to any credit under section 24, 25A, or 32 for the taxable year in which such disallowance period was imposed if the deficiency relates to such taxable year, and

(B)

to determine whether any such disallowance period should be imposed if claim therefor is asserted by the Secretary in the answer or an amended answer filed in accordance with the rules of the Tax Court.

(2) Disallowance period

For purposes of this subsection, the term disallowance period has the meaning given such term under section 6751(d).

(2) Effective date

The amendments made by this subsection apply to petitions filed on or after the date of enactment of this Act.

(3) Transition rule for review of previously imposed disallowance periods

(1) In general

Section 7491(c) is amended—

(2) Effective date

The amendments made by this subsection shall apply to court proceedings beginning after the date that is 36 months after the date of the enactment of this Act in connection with disallowance periods (as defined in section 6751(d) of the Internal Revenue Code of 1986, as added by this Act) determined after such date.

(1) Child tax credit

Section 24(g)(1) is amended—

(2) American opportunity tax credit

Section 25A(b)(4)(A) is amended—

(3) Earned income tax credit

Section 32(k)(1) is amended—

(4) Suspension of running of limitations period filing of a claim for credit or refund

Section 6511(d) is amended by adding at the end the following new paragraph:

(9) Special rules relating to disallowance periods

The running of the periods described in subsections (a) and (b)(2) with respect to any claim for a credit allowed under section 24, 25A, or 32 for any taxable year in a disallowance period (as defined in section 6751(d)) shall be suspended during any period in which the imposition of such disallowance period is pending before the Tax Court.

(5) Effective date

(1) Treatment of deadlines

Section 7451 is amended by redesignating subsection (b) as subsection (c) and by inserting after subsection (a) the following new subsection:

(b) Treatment of deadlines for certain petitions

The deadlines for filing petitions under sections 6015(e)(1)(A), 6213(a), and 6330(d)(1)(A) shall be considered nonjurisdictional claims-processing rules subject to waiver, forfeiture, estoppel and equitable tolling.

(2) Conforming amendment

Section 7459(d) is amended—

(1)

any case brought under section 6015(e)(1)(A), 6213(a), or 6330(d)(1)(A) of the Internal Revenue Code of 1986 for which there is a final determination by the Tax Court before the date of the enactment of this Act, or

(2)

any other petition filed with the Tax Court under any other provision of the Internal Revenue Code of 1986 before, on, or after such date.

(1)

by striking The person may and inserting the following:

(A) In general

The person may,

(2)

by inserting and, unless a challenge was precluded under subsection (c), with respect to the determination of any overpayments of tax for the taxable periods or events at issue in the determination after matter, and

(3)

by adding at the end the following new subparagraphs:

(B) Determination and enforcement of overpayments

Rules similar to the rules of paragraphs (1) and (2) of section 6512(b) shall apply for purposes of this paragraph.

(C) Limitation on amount of credit or refund

(i) In general

In the case of any petition under subparagraph (A), no credit or refund shall be allowed or made of any portion of the tax unless the Tax Court determines as part of its decision that such portion was paid—

(I)

after the notice described in subsection (a)(1) or section 6320(a)(1) (as the case may be) was given,

(II)

within the period which would be applicable under section 6511(b)(2), (c), or (d), if, on the date the notice described in subsection (a)(1) or section 6320(a)(1) (as the case may be) was given, a claim had been filed (whether or not filed) stating the grounds upon which the Tax Court finds that there is an overpayment, or

(III)

within the period which would be applicable under section 6511(b)(2), (c), or (d), in respect of any claim for refund filed within the applicable period specified in section 6511 and before the date the notice described in subsection (a)(1) or section 6320(a)(1) (as the case may be) was given—

(aa)

which had not been disallowed before that date,

(bb)

which had been disallowed before that date and in respect of which a timely suit for refund could have commenced as of that date, or

(cc)

in respect of which a suit for refund had been commenced before that date and within the period specified in section 6532.

In a case described in subclause (II) where the date the notice described in subsection (a)(1) or section 6320(a)(1) (as the case may be) is given is during the third year after the due date (determined without regard to any extensions) for filing the return of tax and no return was filed before such date, the applicable period under subsections (a) and (b)(2) of section 6511 shall be 3 years.

(ii) Date notice was given

For purposes of this subparagraph—

(I)

if notice was given under subsection (a)(2) or section 6320(a)(2) by mail, the date the notice was given shall be the date such notice was mailed, and

(II)

if notice was given under subsection (a)(2) or 6320(a)(2) by leaving such notice at the dwelling or usual place of business of the person, the date the notice was given shall be the date such notice was left.

(1)

by striking The Tax Court and inserting the following:

(a) In general

The Tax Court, and

(2)

by adding at the end the following new subsection:

(b) Actions for refunds

(1) Jurisdiction

(A) In general

In addition to any other court authorized by law, the Tax Court shall, subject to section 7422, have jurisdiction over any action, not exceeding the applicable amount, for the recovery of any internal revenue tax alleged to have been erroneously or illegally assessed or collected, or any penalty claimed to have been collected without authority or of any sum alleged to have been excessive or in any manner wrongfully collected under the internal revenue laws to the same extent as the district courts of the United States.

(B) Applicable amount

For purposes of this paragraph, the applicable amount means—

(i)

$2,000,000 for any one taxable year, in the case of taxes imposed by subtitle A,

(ii)

$2,000,000, in the case of the tax imposed by chapter 11,

(iii)

$2,000,000 for any one calendar year, in the case of the tax imposed by chapter 12,

(iv)

$2,000,000 for any 1 taxable period (or, if there is no taxable period, taxable event) in the case of any tax imposed by subtitle C, D, or E, and

(v)

$2,000,000, in the case of any other amount collected.

(2) Further notice of deficiency

If the Secretary prior to the hearing of a suit brought by a taxpayer under paragraph (1) mails to the taxpayer a notice that a deficiency has been determined in respect of the tax which is the subject matter of the taxpayer's suit, the proceedings in the taxpayer's suit shall be stayed during the period of time in which the taxpayer may file a petition with the Tax Court for a redetermination of the asserted deficiency, and for 60 days thereafter. If the taxpayer files such a petition with the Tax Court, such petition shall be consolidated with the suit brought under paragraph (1).

(1)

Section 7422(k) is amended by adding at the end the following new paragraph:

(5)

For jurisdiction of the Tax Court, see section 7442(b).

(2)

Section 7482(b)(1) is amended by striking or at the end of subparagraph (F), by striking the period at the end of subparagraph (G) and inserting , or, and by adding at the end the following new subparagraph:

(H)

in the case of a petition under section 7442(b)—

(i)

the legal residence of the petitioner if the petitioner is an individual, and

(ii)

the principal place of business or principal office or agency if the petitioner is an entity other than an individual.

(3)

Section 1346(a) of title 28, United States Code, is amended—

(1)

by striking $50,000 each place it appears in subsections (a) and (f) and inserting $100,000, and

(2)

by adding at the end the following new subsection:

(g) Inflation adjustment

(1) In general

In the case of any petition or appeal filed in a calendar year beginning after 2026, each of the $100,000 amounts in subsections (a) and (f) shall be increased by an amount equal to—

(A)

such dollar amount, multiplied by

(B)

the cost-of-living adjustment determined under section 1(f)(3) for the calendar year, determined by substituting calendar year 2025 for calendar year 2016 in subparagraph (A)(ii) thereof.

(2) Rounding

If any increase determined under paragraph (1) is not a multiple of $1,000, such increase shall be rounded to the next lowest multiple of $1,000.

(1)

The heading for section 7463 is amended by striking Disputes involving $50,000 or less and inserting Small disputes.

(2)

The item relating to section 7463 in the table of section for part II of subchapter C of chapter 76 is amended by striking Disputes involving $50,000 or less and inserting Small disputes.

(A)

in subclause (I), by striking and at the end,

(B)

in subclause (II), by striking the period at the end and inserting ; and, and

(C)

by adding at the end the following:

(III)

appoint counsel in the Office of the Taxpayer Advocate to report directly to the National Taxpayer Advocate or delegate thereof., and

(1)

in subclause (XII), by striking and at the end,

(2)

in subclause (XIII), by striking the period at the end and inserting ; and, and

(3)

by adding at the end the following new subclause:

(XIV)

identify any failure by the Commissioner to provide access to any information, advice, or meeting described in subparagraph (A) of paragraph (6) by the date required under subparagraph (B) of such paragraph.

(1)

by striking subsection (d), and

(2)

by redesignating subsections (e) through (g) as subsections (d) through (f), respectively.

(1)

by striking subsection (c) and inserting the following:

(c) Failure To furnish valid identifying number

(1) In general

(A) Penalty

Any person who is a tax return preparer with respect to any return or claim for refund and who fails to furnish an identifying number which complies with section 6109(a)(4)(A) with respect to such return or claim shall pay a penalty of $250 for such failure.

(B) Non-compliance

For purposes of this paragraph, an identifying number shall be deemed to not comply with section 6109(a)(4)(A) if such identifying number—

(i)

is assigned to another person,

(ii)

does not exist,

(iii)

is inactive or expired,

(iv)

has been withdrawn,

(v)

is suspended or has been revoked, or

(vi)

is otherwise invalid for use by the tax return preparer.

(2) Exception

The penalty imposed under paragraph (1) shall not apply if it is shown that such failure is due to reasonable cause and not due to willful neglect.

(3) Limitation

The maximum penalty imposed under this subsection on any person with respect to documents filed during any calendar year shall not exceed $75,000.,

(2)

by redesignating subsection (h) as subsection (i),

(3)

by inserting after subsection (g) the following new subsection:

(h) Use of invalid or appropriated electronic filing identification number

(1) In general

Any person who is an electronic return originator with respect to any return or claim for refund who fails to use, with respect to such return or claim, an electronic filing identification number which is assigned to such person by the Secretary, shall pay a penalty of $250 for such failure, unless it is shown that such failure is due to reasonable cause and not due to willful neglect.

(2) Definitions

For purposes of this subsection—

(A) Electronic return originator

(i) In general

The term electronic return originator means a person who originates the electronic submission of 1 or more returns or claims for refund on behalf of other taxpayers.

(ii) Exceptions

The term electronic return originator shall not include a person merely because such person originates an electronic submission described in clause (i)—

(I)

by providing services which are limited to typing, reproduction, or other mechanical assistance to a person described in such subclause,

(II)

at the direction of an employer (or of an officer or employee of the employer) by whom such person is regularly and continuously employed,

(III)

as a fiduciary, or

(IV)

in response to a determination by the Secretary that directly or indirectly affects the tax liability of a taxpayer.

(B) Electronic filing identification number

(i) In general

The term electronic filing identification number means an identification number assigned by the Secretary to a person authorized to file returns in electronic format on behalf of other taxpayers.

(ii) Suspension or revocation

In the case of any electronic filing identification number which has been suspended or revoked by the Secretary, such number shall not be deemed valid for purposes of paragraph (1)., and

(4)

in subsection (i)(1), as redesignated by paragraph (2), by striking and (g) and inserting (g), and (h).

(1)

by striking subparagraph (A) and inserting the following:

(A) In general

The term tax return preparer means any person who prepares for compensation, or who employs one or more persons to prepare for compensation, any return of tax imposed by this title, any document purporting to be a return of tax imposed by this title, or any claim for refund of tax imposed by this title. For purposes of the preceding sentence, the preparation of a substantial portion of a return, document purporting to be a return, or claim for refund shall be treated as if it were the preparation of such return, document purporting to be a return, or claim for refund., and

(2)

in subparagraph (B)—

(1) In general

Not later than 18 months after the date of enactment of this Act, the Secretary shall establish a program to improve voluntary compliance with respect to requirements under subsections (c) and (h) of section 6695 of the Internal Revenue Code of 1986 (as amended by this section) and avoid the imposition of penalties under such subsections.

(2) Consultation

The program described in paragraph (1) shall be established by the Secretary following consultation with—

(3) Opportunity to correct

For purposes of the program described in paragraph (1), the Secretary shall—

(1) In general

Part I of subchapter A of chapter 75 is amended by adding at the end the following new section:

7218. Willful failure to provide a valid preparer identification number

(a) In general

Any tax return preparer who, with respect to any return, document purporting to be a return, or claim for refund willfully fails to furnish an identifying number which complies with section 6109(a)(4)(A) with respect to such return or document or willfully furnishes a preparer tax identification number which is described in section 6695(c)(1)(B) with intent to evade or defeat the application of any requirement under any provision of this title which requires such preparer to obtain and furnish such number, shall, in addition to any other penalties provided by law, be guilty of a felony and, upon conviction thereof, shall be fined not more than $50,000 ($100,000 in the case of a corporation), or imprisoned not more than 3 years, or both, together with the costs of prosecution.

(b) Preparer tax identification number

In this section, the term preparer tax identification number means an identifying number described in section 6109(a)(4)(A).

(2) Clerical amendment

The table of sections for part I of subchapter A of chapter 75 is amended by adding at the end the following new item:

(1)

in subsection (a)—

(2)

in subsection (b)—

(3)

in subsection (d)—

(4)

in subsection (e)—

(5)

in subsection (g), by striking $500 and inserting $1,000, and

(6)

in subsection (i)(1)—

(1) In general

Subsection (f) of section 6695 is amended to read as follows:

(f) Misappropriation

(1) In general

Any person who is a tax return preparer who misappropriates any payment made in respect of the taxes imposed by this title which is issued to a taxpayer (other than the tax return preparer) shall pay a penalty in an amount determined under paragraph (2).

(2) Penalty

The amount of the penalty determined under this paragraph shall, with respect to each payment described in paragraph (1), be equal to the greater of—

(A)

$1,000, or

(B)

the full amount of such payment.

(3) Exception

Paragraph (1) shall not apply with respect to the deposit by a bank (within the meaning of section 581) of the full amount of the payment in the taxpayer's account in such bank for the benefit of the taxpayer.

(2) Conforming amendment

Section 6695(i)(1) is amended by striking (f), and inserting (f)(2)(A),.

(1)

in subsection (a), by striking paragraph (4) and inserting the following:

(4) Furnishing identifying number of tax return preparer

(A) In general

Any return, claim for refund, or document purporting to be a return or claim for refund which is prepared by a tax return preparer shall bear such identifying number for securing proper identification of such preparer, their employer, or both, as may be prescribed.

(B) Suspension or revocation

In the case of any identifying number which has been suspended or revoked by the Secretary under subsection (e), such number shall not be deemed valid for purposes of subparagraph (A).

(C) Definitions

For purposes of this section—

(i) Specified practitioner

The term specified practitioner means a certified public accountant, attorney, or enrolled agent—

(I)

who is—

(aa)

in good standing with the Department of the Treasury and State licensing authorities, and

(bb)

authorized to represent persons before the Department of the Treasury under section 330 of title 31, United States Code, and

(II)

whose professional license or certification has not been revoked or suspended.

(ii) Return; claim for refund

The terms return and claim for refund have the respective meanings given to such terms by section 6696(e)., and

(2)

by inserting after subsection (d) the following:

(e) Identifying number of tax return preparer

(1) In general

The Secretary shall maintain a program for administration of preparer tax identification numbers required under subsection (a)(4), which shall include restrictions on the issuance of such numbers to any individual other than an individual who—

(A)

meets the suitability requirements of paragraph (2) and the education requirements of paragraph (3),

(B)

meets the state program requirements of paragraph (4), or

(C)

is a specified practitioner.

(2) Demonstration of suitability

(A) In general

An individual meets the suitability requirements of this paragraph if such individual has demonstrated to the Secretary the individual's suitability to be a tax return preparer by—

(i)

providing such information as the Secretary determines necessary, and

(ii)

passing a background check, including a review by the Secretary regarding compliance with personal tax obligations.

(B) Conduct demonstrating lack of suitability

For purposes of subparagraph (A), an individual shall be deemed to have failed to demonstrate their suitability to be a tax return preparer if—

(i)

any license or registration issued to such individual by a State to prepare tax returns has been suspended or revoked by such State, or

(ii)

the Secretary determines that such individual is described in clauses (ii) through (vi) of paragraph (5)(A).

(C) Regulations and guidance

The Secretary shall issue such regulations or other guidance as the Secretary determines necessary to carry out the purposes of this paragraph.

(D) Prohibition on examinations

For purposes of subparagraph (A), except as provided in paragraph (3)(C)(iii), the Secretary may not require an examination as a prerequisite for the assignment or renewal of a preparer tax identification number.

(E) Grandfathering of prior background checks

(i) In general

Subject to clause (ii), for purposes of subparagraph (A)(ii), in the case of a class of individuals (as identified by the Secretary) who have passed a background check prior to the date of enactment of this subsection, the Secretary may deem such class of individuals to have satisfied the requirement under such subparagraph.

(ii) Nonapplication to requirement regarding compliance with personal tax obligations

Clause (i) shall not apply with respect to review by the Secretary under subparagraph (A)(ii) regarding compliance with personal tax obligations.

(3) Educational programs

(A) In general

An individual shall meet the education requirements of this paragraph if such individual completes a specified number of hours of educational programs on ethics, professional responsibility, and tax law (including recently enacted Federal income tax legislation) as required by the Secretary prior to the assignment or renewal of a preparer tax identification number.

(B) Additional educational requirements for renewal

The Secretary may require any individual seeking the renewal of a preparer tax identification number to complete educational programs in addition to those required under subparagraph (A). Any educational programs required under this subparagraph shall be based on—

(i)

a review of returns which include the preparer tax identification number of such preparer, and

(ii)

any errors identified by the Secretary as part of the review described in clause (i).

(C) Other requirements

For purposes of this paragraph, the Secretary—

(i)

may not require a tax return preparer to annually complete more than 18 hours of educational programs,

(ii)

shall require that any educational program include written materials which satisfy such standards as are established by the Secretary,

(iii)

shall require that any educational program include a method to ensure that the tax return preparer attended the program and sufficiently understood the material presented, and

(iv)

may not direct any educational program to be completed through a specific provider.

(D) Notice of failure to timely complete requirements

The Secretary shall provide any tax return preparer who fails to complete the requirements of this paragraph notice of such failure and a 30-day period in which to cure such failure.

(E) Publication of approved courses

The Secretary shall publish, on the public website of the Internal Revenue Service—

(i)

a list of educational programs which have been determined by the Secretary to satisfy the requirement under clause (ii) of subparagraph (C) (and, if applicable, the requirement under clause (iii) of such subparagraph), including the providers of such programs, and

(ii)

any such requirements as the Secretary deems necessary to impose with respect to any additional programs required under subparagraph (B), provided that such requirements are similar to the requirements provided under section 330 of title 31, United States Code, or regulations prescribed thereunder.

(4) Exemption

(A) In general

Subject to subparagraph (B), any individual meets the state program requirements of this paragraph if such individual maintains a valid State license or registration issued by a State licensing program or State registration program (including State tax education councils) which includes examination, education, and background check requirements that are comparable to the suitability requirements described in paragraph (2) and the education requirements described in paragraph (3).

(B) Grandfathering of certain programs

For purposes of subparagraph (A), with respect to determining whether a State licensing program or State registration program (including State tax education councils) includes examination, education, and background check requirements which are comparable to the suitability requirements described in paragraph (2) and the education requirements described in paragraph (3), such determination shall be made by the Secretary without regard to whether such requirements were included in such program at the time that such individual was licensed or registered under such program, provided that such requirements are, as of the date that such individual requested assignment or renewal of a preparer tax identification number under this subsection, presently included in such program.

(5) Authority to revoke or suspend preparer tax identification number

(A) In general

The Secretary may suspend or revoke a preparer tax identification number if, after notice and opportunity for a hearing, the Secretary makes a determination that the tax return preparer—

(i)

has not met—

(I)

the suitability requirements of paragraph (2) and the education requirements of paragraph (3), or

(II)

the state program requirements of paragraph (4),

(ii)

is incompetent, as demonstrated by a repeated pattern of errors in returns that were prepared by such preparer which affected the determination of tax liability in such returns,

(iii)

is disreputable, as demonstrated by—

(I)

giving false or misleading information under paragraph (2)(A)(i),

(II)

willful failure to comply with personal tax obligations,

(III)

an unpaid tax delinquency—

(aa)

which is outstanding for greater than 180 days,

(bb)

which is not being actively disputed, and

(cc)

which is not—

(AA)

subject to an agreement or compromise under section 6159 or 7122,

(BB)

classified as currently not collectible (within the meaning of section 6343(e)), or

(CC)

subject to a pending application for such an agreement, compromise, or status,

(IV)

revocation or suspension of any license or registration issued by a State for the preparation of tax returns,

(V)

conviction of any criminal offense—

(aa)

involving dishonesty or breach of trust, or

(bb)

which is punishable under this title,

(VI)

a final determination of liability for a penalty pursuant to section 6694, 6695(h), 6700, 6701, 6702, or 6713,

(VII)

subject to an injunction under section 7407 or 7408, or

(VIII)

any conduct similar to the conduct described in subclauses (I) through (VII), as provided under regulations prescribed by the Secretary,

(iv)

in the case of a person subject to regulation under section 330 of title 31, United States Code, or regulations prescribed thereunder, has violated the requirements under such section or such regulations,

(v)

with intent to defraud, willfully and knowingly misleads or threatens—

(I)

the person whose return or claim for refund is being prepared, or

(II)

a prospective person seeking for a return or claim for refund to be prepared, or

(vi)

has engaged in conduct (as identified in regulations or guidance issued by the Secretary) which is similar to the conduct described in clauses (i) through (v) and that the denial, suspension, or revocation of such number would promote compliance with the requirements of this title and effective tax administration.

(B) Monetary penalty

(i) In general

In addition to, or in lieu of, any suspension or revocation of a preparer tax identification number under subparagraph (A), the Secretary may impose a penalty in any amount not exceeding $5,000.

(ii) Reduction

Any penalty imposed under clause (i) shall be reduced by the amount of any penalty imposed under section 6694, 6695, 6700, 6701, 6702, or 6713 with regard to the same conduct.

(iii) Adjustment for inflation

(I) In general

In the case of any penalty imposed during any calendar year beginning after 2025, the dollar amount in clause (i) shall be increased by an amount equal to—

(aa)

such dollar amount, multiplied by

(bb)

the cost-of-living adjustment determined under section 1(f)(3) for the calendar year, determined by substituting calendar year 2024 for calendar year 2016 in subparagraph (A)(ii) thereof.

(II) Rounding

If any amount determined under subclause (I) is not a multiple of $100, such amount shall be rounded to the nearest multiple of $100.

(C) Reinstatement

The Secretary shall, through regulations or other guidance, establish procedures to allow any tax return preparer whose preparer tax identification number has been suspended or revoked pursuant to subparagraph (A) to have such number reissued (or, in the case of a suspension, for such suspension to be terminated), provided that such preparer demonstrates, to the satisfaction of the Secretary, that—

(i)

the conduct described in such paragraph which was the basis for such suspension or revocation has been sufficiently addressed or resolved (such as through completion of educational programs described in paragraph (3) or reinstatement of a license issued by a State for the preparation of tax returns), and

(ii)

effective tax administration would be promoted by terminating the suspension of such number or reissuing such number to such preparer.

(D) Preliminary suspension

(i) In general

After notice and opportunity to respond, the Secretary may suspend the preparer tax identification number of a tax return preparer for a period of not greater than 180 days if the Secretary determines that—

(I)

such tax return preparer has engaged in any conduct described in clauses (i) through (vi) of subparagraph (A), and

(II)

such suspension is necessary to prevent serious economic harm to taxpayers or serious impairment of effective tax administration, such as to prevent the filing of fraudulent returns or claims for refund.

(ii) Limitation

For purposes of clause (i), if the preparer tax identification number of a tax return preparer has been suspended pursuant to such clause 2 times during any 5-year period, the Secretary may not issue an additional suspension pursuant to such clause with respect to such preparer during such period unless such suspension is subsequent to a determination by the Secretary to suspend or revoke the preparer tax identification number of such preparer pursuant to subparagraph (A).

(E) Regulations

Not later than 24 months after the date of enactment of this subsection, the Secretary shall issue such regulations or other guidance as the Secretary determines necessary to carry out the purposes of this paragraph, including—

(i)

guidelines that identify the particular penalty applicable to any conduct described in subparagraph (A), and

(ii)

the manner of notice and opportunity to respond for purposes of subparagraph (D).

(F) No inference

Nothing in this paragraph shall be construed to create any inference with respect to the definition or meaning of any term used in section 330 of title 31, United States Code, or regulations prescribed thereunder.

(6) Appeal

In the case of any tax return preparer for whom the Secretary has made a determination—

(A)

that such preparer has not met the requirements of paragraphs (2) and (3) or of paragraph (4) and that issuance of a preparer tax identification number should be denied,

(B)

under paragraph (5)(A) that the preparer tax identification number for such preparer should be suspended or revoked, or

(C)

that a penalty should be imposed pursuant to paragraph (5)(B),

such preparer shall be provided with an opportunity to appeal such determination pursuant to procedures (as established by the Secretary through regulations or other guidance) which are similar to the procedures provided under section 330 of title 31, United States Code, and regulations prescribed thereunder.

(7) Disclosure of final determinations

(A) In general

In the case of any determination—

(i)

in which an extended suspension or revocation of a preparer tax identification number is imposed under this subsection, and

(ii)

for which all administrative and judicial appeals are exhausted,

not later than 30 days following such determination, the Secretary shall publish such determination on the public website of the Internal Revenue Service, which shall include a statement of the facts and circumstances relating to such determination and the reasons for the determination.

(B) Extended suspension

For purposes of subparagraph (A), the term extended suspension means a suspension issued by the Secretary pursuant to paragraph (5)(A) for a period of greater than 180 days.

(8) Preparer tax identification number

For purposes of this subsection, the term preparer tax identification number means an identifying number described in subsection (a)(4)(A).

(1)

by redesignating subsection (e) as subsection (f); and

(2)

by inserting after subsection (d) the following:

(e) Disclosure of final determinations

In the case of any determination under subsection (c) or (d)—

(1)

in which a suspension, disbarment, or censure, or other penalty is imposed, and

(2)

for which all administrative and judicial appeals are exhausted,

not later than 30 days following such determination, the Secretary shall publish such determination on a public website, which shall include a statement of the facts and circumstances relating to such determination and the reasons for the determination.

(1) In general

Section 6103(k) is amended by adding at the end the following new paragraph:

(16) Disclosure relating to misconduct by practitioners and tax return preparers

Under such procedures as the Secretary may prescribe, the Secretary may disclose returns and return information to the extent the Secretary determines it is necessary to publish determinations pursuant to section 6109(e)(7) and section 330(e) of title 31, United States Code, provided that such disclosure is redacted to remove—

(A)

any name, address, or other identifying information with respect to any persons other than the representative or tax return preparer who is the subject of such determination, and

(B)

such other information as the Secretary determines appropriate to protect the privacy of such persons.

(2) Conforming amendment

Section 6103(p)(3)(A) is amended by striking or (9) and inserting (9), or (16).

(1) In general

Section 6109(a) is amended by inserting after paragraph (4) the following new paragraph:

(5) Furnishing identifying number for offer-in-compromise

Any offer-in-compromise (as described in section 7122), including any required schedule or statement, which has been prepared by any person for compensation shall include such identifying number as may be prescribed for securing proper identification of such person.

(2) Penalty

Section 7122 is amended by adding at the end the following new subsection:

(h) Failure To furnish identifying number

(1) In general

(A) Penalty

Any person who prepares an offer-in-compromise (including any required schedule or statement) for compensation and who fails to include an identifying number which complies with section 6109(a)(5) with respect to such offer-in-compromise shall pay a penalty of $250 for such failure.

(B) Non-compliance

For purposes of this paragraph, an identifying number shall be deemed to not comply with section 6109(a)(5) if such identifying number—

(i)

is assigned to another person,

(ii)

does not exist,

(iii)

is inactive or expired,

(iv)

has been withdrawn,

(v)

is suspended or has been revoked, or

(vi)

is otherwise invalid for use by the preparer.

(C) Adjustment for inflation

(i) In general

In the case of any documents filed during any calendar year beginning after 2025, the $250 amount in subparagraph (A) shall be increased by an amount equal to—

(I)

such dollar amount, multiplied by

(II)

the cost-of-living adjustment determined under section 1(f)(3) for the calendar year, determined by substituting calendar year 2024 for calendar year 2016 in subparagraph (A)(ii) thereof.

(ii) Rounding

If any amount determined under clause (i) is not a multiple of $10, such amount shall be rounded to the nearest multiple of $10.

(2) Exception

The penalty imposed under paragraph (1) shall not apply if it is shown that such failure is due to reasonable cause and not due to willful neglect.

(3) Limitation

(A) In general

The maximum penalty imposed under this subsection on any person with respect to documents filed during any calendar year shall not exceed $75,000.

(B) Adjustment for inflation

(i) In general

In the case of any penalty imposed during any calendar year beginning after 2025, the $75,000 amount in subparagraph (A) shall be increased by an amount equal to—

(I)

such dollar amount, multiplied by

(II)

the cost-of-living adjustment determined under section 1(f)(3) for the calendar year, determined by substituting calendar year 2024 for calendar year 2016 in subparagraph (A)(ii) thereof.

(ii) Rounding

If any amount determined under clause (i) is not a multiple of $1,000, such amount shall be rounded to the nearest multiple of $1,000.

(4) Other applicable rules

Rules similar to the rules of section 6696 shall apply for purposes of this subsection.

(1) In general

Not later than 18 months after the date of the enactment of this Act, the Comptroller General of the United States shall conduct a study and submit to Congress a report on the sharing of information between the Secretary and State authorities, as authorized under subsections (d) and (k)(5) of section 6103 of the Internal Revenue Code of 1986, regarding identification numbers issued to paid tax return preparers and return preparer minimum standards.

(2) Increased information sharing

The study and report described in paragraph (1) shall include an analysis of the impact that increased information sharing between Federal and State authorities would have on efforts to enforce minimum standards on paid tax return preparers.

(3) Audit of Internal Revenue Service

Section 6103(i)(8) is amended by adding at the end the following new subparagraph:

(D) Application to study conducted under Taxpayer Assistance and Service Act

For purposes of this paragraph, the study and report described in section 504(e)(1) of the Taxpayer Assistance and Service Act shall be deemed to be an audit of the Internal Revenue Service.

(1)

the 10 most frequent errors found on tax returns which were prepared by tax return preparers (as defined in section 7701(a)(36) of the Internal Revenue Code of 1986) during the most recent calendar year for which data is available, and

(2)

with respect to the preceding calendar year, the top 10 reasons that tax return preparers were—

(1)

which, pursuant to section 330 of title 31, United States Code, permits a tax return preparer to represent a taxpayer before the Department of the Treasury in cases in which such preparer prepared and signed the return of tax, or

(2)

for publication of a public database on the website of the Internal Revenue Service of tax return preparers who have satisfied the requirements for issuance of a preparer tax identification number (as defined in section 6109(e)(8) of the Internal Revenue Code of 1986).

(1) In general

The amendments made by this section shall take effect on the date which is 180 days after the date of enactment of this Act.

(2) Transition rules for educational requirements for tax return preparers

(1)

in paragraph (3)—

(2)

by striking paragraph (4) and inserting the following new paragraph:

(4) Right of appeal

(A) In general

Except as otherwise provided under this title, the resolution process described in paragraph (3) shall be available to all taxpayers with respect to any determination by the Secretary concerning a Federal tax controversy, including—

(i)

liability for, or any claim for refund of, any tax,

(ii)

liability for, or any claim for refund of, any penalty or addition to tax,

(iii)

eligibility for alternatives to collection of a tax liability, such as an agreement or compromise under section 6159 or 7122, or

(iv)

any exercise of discretion by the Secretary with respect to any determination described in clauses (i) through (iii).

(B) Exceptions

Subparagraph (A) shall not apply with respect to any appeal—

(i)

which is solely based on a challenge to the constitutionality or validity of any law, regulation, notice, revenue ruling, or revenue procedure issued by the Secretary, unless there is a final and unreviewable decision rendered by a Federal court that the relevant provision of such law, regulation, notice, revenue ruling, or revenue procedure which is being challenged is unconstitutional or otherwise invalid,

(ii)

which—

(I)

is based on a position which—

(aa)

a Federal court has determined to be frivolous, and

(bb)

the Secretary has identified as frivolous for purposes of subsection (c) of section 6702, or

(II)

relates to any penalty imposed under such section with respect to such position,

(iii)

which relates to any matter agreed upon pursuant to an agreement under section 7121,

(iv)

subject to subparagraph (C), during any period in which—

(I)

the Secretary is actively investigating whether to refer the taxpayer to the Attorney General for criminal prosecution,

(II)

a recommendation made by the Secretary to the Attorney General for the criminal prosecution of the taxpayer for any offense connected with the administration or enforcement of the internal revenue laws is pending, or

(III)

any criminal prosecution of the taxpayer, or of any other person in a case in which the taxpayer is a witness, for any offense connected with the administration or enforcement of the internal revenue laws is pending, or

(v)

with respect to any issue in a case which, based on the relevant facts and circumstances of such case, the Chief Counsel for the Internal Revenue Service—

(I)

has designated for litigation, and

(II)

is prepared to proceed with such litigation in a timely manner.

(C) Exception for certain criminal prosecutions

Subparagraph (B)(iv) shall not apply if the Chief Counsel for the Internal Revenue Service determines that the resolution process described in paragraph (3) would not interfere with the criminal prosecution of a taxpayer.

(D) Federal tax controversy

For purposes of this paragraph, the term Federal tax controversy means a dispute described in paragraph (2) or (3) of section 301.7803–2 of title 26, Code of Federal Regulations (as in effect on the date of enactment of the Taxpayer Assistance and Service Act).

(1)

by striking appealed to and inserting reviewed by; and

(2)

by adding at the end the following: Any review by the Tax Court under the preceding sentence shall be de novo and shall be based on the administrative record established at the time of the original determination and any additional newly discovered or previously unavailable evidence..

(1)

by redesignating subsection (k) as subsection (l); and

(2)

by inserting after subsection (j) the following:

(k) Awards to whistleblowers

An award authorized under section 7623 of the Internal Revenue Code of 1986 shall be exempt from reduction under any order issued under this part.

(1) In general

The amendments made by this section shall take effect 180 days after the date of the enactment of this Act.

(2) Special rule

If, as of the date described in paragraph (1)—

the applicable date for purposes of such paragraph (7)(C) is the date that is 12 months after the date described in paragraph (1).

(1)

in the heading, by inserting and payment after filing,

(2)

in paragraph (2)—

(3)

by adding at the end the following:

(3) Electronic filing and payment

(A) In general

In the case of any document or payment which the Secretary has permitted to be filed or made by electronic means, if such document or payment is—

(i)

authorized to be submitted by the taxpayer using a permitted electronic means to the agency, officer, or office to which the document was required to be filed (or payment was required to be made) on or before the prescribed date (or within the period required) with respect to such document or payment, and

(ii)

received (or, in the case of a payment, received and accounted for) no later than 3 business days after the prescribed date or period required with respect to such document or payment,

the date that such document or payment was authorized to be submitted (as described in clause (i)) shall be deemed to be the date that such document was filed or such payment was made.

(B) Exception

This paragraph shall not apply to any payment if Secretary determines that the taxpayer (or any intermediary used by the taxpayer) used a system designed with a principal purpose of delaying the transfer of funds to the Treasury to derive economic benefit from the period of such delay.

(C) Regulations

Not later than the date which is 1 year after the date of enactment of the Taxpayer Assistance and Service Act, the Secretary shall issue such regulations or other guidance as the Secretary determines necessary to carry out the purposes of this paragraph, including regulations or other guidance describing the records or proof sufficient to demonstrate timely electronic submission.

(b) Effective date

The amendments made by subsection (a) shall apply to any document or payment sent on or after the date which is 1 year after the date of enactment of this Act.

(1)

by striking and at the end of subparagraph (A),

(2)

by redesignating subparagraph (B) as subparagraph (C) and by inserting after subparagraph (A) the following new subparagraph:

(B)

in any case in which the information sought to be obtained from such other persons could reasonably be provided by the taxpayer, identifies the item of information intended to be sought from such persons, and, and

(3)

by amending subparagraph (C), as redesignated by paragraph (2), to read as follows:

(C)

provides the taxpayer with reasonable opportunity and a period of not less than 45 days (or more, if the taxpayer requests additional time and shows reasonable cause) to respond, including by providing the information described in subparagraph (B), before contact is made with such other persons.

(1)

by redesignating subparagraphs (A), (B), and (C) as clauses (i), (ii), and (iii), respectively, and by moving such clauses 2 ems to the right,

(2)

by striking This subsection and inserting the following:

(A) In general

This subsection, and

(3)

by adding at the end the following new subparagraph:

(B) Good cause

For purposes of subparagraph (A)(ii), good cause includes a reasonable belief that compliance with this subsection will lead to—

(i)

attempts by any person to conceal, remove, destroy, or alter records or assets that may be relevant to any tax examination or collection activity;

(ii)

attempts by any person to prevent other persons, through intimidation, bribery, or collusion, from communicating any information that may be relevant to any tax examination or collection activity; or

(iii)

attempts by any person to flee, or otherwise avoid testifying or producing records that may be relevant to any tax examination or collection activity.

(1)

regarding redisclosures of return information under subparagraph (D)(vii) of section 6103(l)(13) of the Internal Revenue Code of 1986 (as added by this section), including the number of such redisclosures; and

(2)

regarding any unauthorized use, access, or disclosure of return information disclosed under such section.

(1)

by striking the first paragraph (6), as added by section 2301(b) of the Taxpayer First Act, and inserting the following:

(6) Partnerships required to file on magnetic media

Notwithstanding paragraph (2)(A), the Secretary shall require a partnership to file returns on magnetic media if, at the close of the partnership's taxable year—

(A)

the partnership has more than 50 partners, or

(B)

the value of the partnership’s assets equals or exceeds $1,000,000, as determined under regulations prescribed by the Secretary., and

(2)

by redesignating the second paragraph (6), as added by section 202(d) of the Setting Every Community Up for Retirement Enhancement Act of 2019, as paragraph (7).