United States HR 6323: Taxpayer Protection and Preparer Proficiency Act

Bill Text

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119TH CONGRESS
1ST SESSION H. R. 6323
To amend the Internal Revenue Code of 1986 to penalize improper compliance
with certain taxpayer requirements, and for other purposes.
IN THE HOUSE OF REPRESENTATIVES
NOVEMBER 28, 2025
Mr. PANETTA (for himself and Mr. STEUBE) introduced the following bill;
which was referred to the Committee on Ways and Means
A BILL
To amend the Internal Revenue Code of 1986 to penalize
improper compliance with certain taxpayer requirements,
and for other purposes.
Be it enacted by the Senate and House of Representa-1
tives of the United States of America in Congress assembled, 2
SECTION 1. SHORT TITLE; ETC. 3
(a) SHORT TITLE.—This Act may be cited as the 4
‘‘Taxpayer Protection and Preparer Proficiency Act’’. 5
(b) REFERENCES TO INTERNAL REVENUE CODE.— 6
Except as otherwise expressly provided, whenever in this 7
Act an amendment is expressed in terms of an amendment 8
to a section or other provision, the reference shall be con-9
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sidered to be made to a section or other provision of the 1
Internal Revenue Code of 1986. 2
(c) REFERENCES TO SECRETARY.—For purposes of 3
this Act, the term ‘‘Secretary’’ means the Secretary of the 4
Treasury or the Secretary’s delegate. 5
SEC. 2. PENALTIES FOR TAX RETURN PREPARERS WHO IM-6
PROPERLY ALTER RETURNS. 7
(a) IN GENERAL.—Paragraph (1) of section 6696(e) 8
is amended to read as follows: 9
‘‘(1) RETURN.—The term ‘return’ means— 10
‘‘(A) any return of any tax imposed by this 11
title, 12
‘‘(B) any administrative adjustment re-13
quest under section 6227, 14
‘‘(C) any partnership adjustment tracking 15
report under section 6226(b)(4)(A), and 16
‘‘(D) any other document purporting to be 17
a return, request, or report described in sub-18
paragraphs (A) through (C).’’. 19
(b) EFFECTIVE DATE.—The amendment made by 20
this section shall take effect on the date of enactment of 21
this Act. 22
SEC. 3. PENALTIES FOR INVALID OR APPROPRIATED PRE-23
PARER IDENTIFICATION NUMBERS. 24
(a) IN GENERAL.—Section 6695 is amended— 25
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(1) by striking subsection (c) and inserting the 1
following: 2
‘‘(c) FAILURE TO FURNISH VALID IDENTIFYING 3
NUMBER.— 4
‘‘(1) IN GENERAL.— 5
‘‘(A) PENALTY.—Any person who is a tax 6
return preparer with respect to any return or 7
claim for refund and who fails to furnish an 8
identifying number which complies with section 9
6109(a)(4)(A) with respect to such return or 10
claim shall pay a penalty of $250 for such fail-11
ure. 12
‘‘(B) NON-COMPLIANCE.—For purposes of 13
this paragraph, an identifying number shall be 14
deemed to not comply with section 15
6109(a)(4)(A) if such identifying number— 16
‘‘(i) is assigned to another person, 17
‘‘(ii) does not exist, 18
‘‘(iii) is inactive or expired, 19
‘‘(iv) has been withdrawn, 20
‘‘(v) is suspended or has been revoked, 21
or 22
‘‘(vi) is otherwise invalid for use by 23
the tax return preparer. 24
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‘‘(2) EXCEPTION.—The penalty imposed under 1
paragraph (1) shall not apply if it is shown that 2
such failure is due to reasonable cause and not due 3
to willful neglect. 4
‘‘(3) LIMITATION.—The maximum penalty im-5
posed under this subsection on any person with re-6
spect to documents filed during any calendar year 7
shall not exceed $75,000.’’, 8
(2) by redesignating subsection (h) as sub-9
section (i), 10
(3) by inserting after subsection (g) the fol-11
lowing new subsection: 12
‘‘(h) USE OF INVALID OR APPROPRIATED ELEC-13
TRONIC FILING IDENTIFICATION NUMBER.— 14
‘‘(1) IN GENERAL.—Any person who is an elec-15
tronic return originator with respect to any return 16
or claim for refund who fails to use, with respect to 17
such return or claim, an electronic filing identifica-18
tion number which is assigned to such person by the 19
Secretary, shall pay a penalty of $250 for such fail-20
ure, unless it is shown that such failure is due to 21
reasonable cause and not due to willful neglect. 22
‘‘(2) DEFINITIONS.—For purposes of this sub-23
section— 24
‘‘(A) ELECTRONIC RETURN ORIGINATOR.— 25
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‘‘(i) IN GENERAL.—The term ‘elec-1
tronic return originator’ means a person 2
who originates the electronic submission of 3
1 or more returns or claims for refund on 4
behalf of other taxpayers. 5
‘‘(ii) EXCEPTIONS.—The term ‘elec-6
tronic return originator’ shall not include a 7
person merely because such person origi-8
nates an electronic submission described in 9
cl