< Back to H.R. 661 (104th Congress, 1995–1996)

Text of Taxpayer Bill of Rights 2

This bill was introduced on January 24, 1995, in a previous session of Congress, but was not enacted. The text of the bill below is as of Jan 24, 1995 (Introduced).

Source: GPO

HR 661 IH

104th CONGRESS

1st Session

H. R. 661

To amend the Internal Revenue Code of 1986 to provide additional safeguards to protect taxpayer rights.

IN THE HOUSE OF REPRESENTATIVES

January 24, 1995

Mr. THORNTON 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 provide additional safeguards to protect taxpayer rights.

    Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,

SECTION 1. SHORT TITLE; AMENDMENT OF 1986 CODE; TABLE OF CONTENTS.

    (a) SHORT TITLE- This Act may be cited as the ‘Taxpayer Bill of Rights 2’.

    (b) AMENDMENT OF 1986 CODE- Except as otherwise expressly provided, whenever in this Act an amendment or repeal is expressed in terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1986.

    (c) TABLE OF CONTENTS- The table of contents of this Act is as follows:

      Sec. 1. Short title; amendment of 1986 Code; table of contents.

TITLE I--TAXPAYER ADVOCATE

      Sec. 101. Establishment of position of Taxpayer Advocate within Internal Revenue Service.

      Sec. 102. Expansion of authority to issue taxpayer assistance orders.

TITLE II--MODIFICATIONS TO INSTALLMENT AGREEMENT PROVISIONS

      Sec. 201. Taxpayer’s right to installment agreement.

      Sec. 202. Running of failure to pay penalty suspended during period installment agreement in effect.

      Sec. 203. Notification of reasons for termination or denial of installment agreements.

      Sec. 204. Administrative review of denial of request for, or termination of, installment agreement.

TITLE III--INTEREST

      Sec. 301. Expansion of authority to abate interest.

      Sec. 302. Extension of interest-free period for payment of tax after notice and demand.

TITLE IV--JOINT RETURNS

      Sec. 401. Disclosure of collection activities.

      Sec. 402. Joint return may be made after separate returns without full payment of tax.

TITLE V--COLLECTION ACTIVITIES

      Sec. 501. Modifications to lien and levy provisions.

      Sec. 502. Offers-in-compromise.

      Sec. 503. Notification of examination.

      Sec. 504. Increase in limit on recovery of civil damages for unauthorized collection actions.

      Sec. 505. Safeguards relating to designated summons.

TITLE VI--INFORMATION RETURNS

      Sec. 601. Phone number of person providing payee statements required to be shown on such statement.

      Sec. 602. Civil damages for fraudulent filing of information returns.

      Sec. 603. Requirement to conduct reasonable investigations of information returns.

TITLE VII--MODIFICATIONS TO PENALTY FOR FAILURE TO COLLECT AND PAY OVER TAX

      Sec. 701. Preliminary notice requirement.

      Sec. 702. Disclosure of certain information where more than 1 person subject to penalty.

      Sec. 703. Penalties under section 6672.

TITLE VIII--AWARDING OF COSTS AND CERTAIN FEES

      Sec. 801. Motion for disclosure of information.

      Sec. 802. Increased limit on attorney fees.

      Sec. 803. Failure to agree to extension not taken into account.

      Sec. 804. Authority for court to award reasonable administrative costs.

      Sec. 805. Effective date.

TITLE IX--OTHER PROVISIONS

      Sec. 901. Required content of certain notices.

      Sec. 902. Treatment of substitute returns under section 6651.

      Sec. 903. Relief from retroactive application of Treasury Department regulations.

      Sec. 904. Required notice of certain payments.

      Sec. 905. Unauthorized enticement of information disclosure.

TITLE X--FORM MODIFICATIONS; STUDIES

      Sec. 1000. Definitions.

Subtitle A--Form Modifications

      Sec. 1001. Explanation of certain provisions.

      Sec. 1002. Improved procedures for notifying service of change of address or name.

      Sec. 1003. Rights and responsibilities of divorced individuals.

Subtitle B--Studies

      Sec. 1011. Pilot program for appeal of enforcement actions.

      Sec. 1012. Study on taxpayers with special needs.

      Sec. 1013. Reports on taxpayer-rights education program.

      Sec. 1014. Biennial reports on misconduct by Internal Revenue Service employees.

      Sec. 1015. Study of notices of deficiency.

      Sec. 1016. Notice and form accuracy study.

TITLE I--TAXPAYER ADVOCATE

SEC. 101. ESTABLISHMENT OF POSITION OF TAXPAYER ADVOCATE WITHIN INTERNAL REVENUE SERVICE.

    (a) GENERAL RULE- Section 7802 (relating to Commissioner of Internal Revenue; Assistant Commissioner (Employee Plans and Exempt Organizations)) is amended by adding at the end the following new subsection:

    ‘(d) OFFICE OF TAXPAYER ADVOCATE-

      ‘(1) IN GENERAL- There is established in the Internal Revenue Service an office to be known as the ‘Office of the Taxpayer Advocate’. Such office, including all problem resolution officers, shall be under the supervision and direction of an official to be known as the ‘Taxpayer Advocate’ who shall report directly to the Commissioner of Internal Revenue. The Taxpayer Advocate shall be entitled to compensation at the same rate as the Chief Counsel for the Internal Revenue Service.

      ‘(2) FUNCTIONS OF OFFICE-

        ‘(A) IN GENERAL- It shall be the function of the Office of Taxpayer Advocate to--

          ‘(i) assist taxpayers in resolving problems with the Internal Revenue Service,

          ‘(ii) identify areas in which taxpayers have problems in dealings with the Internal Revenue Service,

          ‘(iii) to the extent possible, propose changes in the administrative practices of

the Internal Revenue Service to mitigate problems identified under clause (ii), and

          ‘(iv) identify potential legislative changes which may be appropriate to mitigate such problems.

        ‘(B) ANNUAL REPORTS-

          ‘(i) OBJECTIVES- Not later than June 30 of each calendar year after 1994, the Taxpayer Advocate shall report to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate on the objectives of the Taxpayer Advocate for the fiscal year beginning in such calendar year. Any such report shall contain full and substantive analysis, in addition to statistical information.

          ‘(ii) ACTIVITIES- Not later than December 31 of each calendar year after 1994, the Taxpayer Advocate shall report to the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate on the activities of the Taxpayer Advocate during the fiscal year ending during such calendar year. Any such report shall contain full and substantive analysis, in addition to statistical information, and shall--

            ‘(I) identify the initiatives the Taxpayer Advocate has taken on improving taxpayer services and Internal Revenue Service responsiveness,

            ‘(II) contain recommendations received from individuals with the authority to issue taxpayer assistance orders under section 7811,

            ‘(III) contain a summary of at least 20 of the most serious problems encountered by taxpayers, including a description of the nature of such problems,

            ‘(IV) contain an inventory of the items described in subclauses (I), (II), and (III) for which action has been taken and the result of such action,

            ‘(V) contain an inventory of the items described in subclauses (I), (II), and (III) for which action remains to be completed and the period during which each item has remained on such inventory,

            ‘(VI) contain an inventory of the items described in subclauses (II) and (III) for which no action has been taken, the period during which each item has remained on such inventory, the reasons for the inaction, and identify any Internal Revenue Service official who is responsible for such inaction,

            ‘(VII) identify any Taxpayer Assistance Order which was not honored by the Internal Revenue Service in a timely manner, as specified under section 7811(b),

            ‘(VIII) contain recommendations for such administrative and legislative action as may be appropriate to resolve problems encountered by taxpayers, and

            ‘(IX) include such other information as the Taxpayer Advocate may deem advisable.

          ‘(iii) REPORT TO BE SUBMITTED DIRECTLY- Each report required under this subparagraph shall be provided directly to the Committees referred to in clauses (i) and (ii) without any prior review or comment from the Commissioner of the Internal Revenue Service, the Secretary of the Treasury, any other officer or employee of the Department of the Treasury, or the Office of Management and Budget.

      ‘(3) RESPONSIBILITIES OF COMMISSIONER OF INTERNAL REVENUE SERVICE- The Commissioner of Internal Revenue shall establish procedures requiring a formal response to all recommendations submitted to the Commissioner by the Taxpayer Advocate.’

    (b) CONFORMING AMENDMENTS-

      (1) Section 7811 (relating to taxpayer assistance orders) is amended--

        (A) by striking ‘the Office of Ombudsman’ in subsection (a) and inserting ‘the Office of the Taxpayer Advocate’, and

        (B) by striking ‘Ombudsman’ each place it appears (including in the headings of

subsections (e) and (f)) and inserting ‘Taxpayer Advocate’.

      (2) The heading for section 7802 is amended to read as follows:

‘SEC. 7802. COMMISSIONER OF INTERNAL REVENUE; ASSISTANT COMMISSIONERS; TAXPAYER ADVOCATE.’

      (3) The table of sections for subchapter A of chapter 80 of subtitle F is amended by striking the item relating to section 7802 and inserting the following new item:

‘Sec. 7802. Commissioner of Internal Revenue; Assistant Commissioners; Taxpayer Advocate.’

    (c) EFFECTIVE DATE- The amendments made by this section shall take effect on the date of the enactment of this Act.

SEC. 102. EXPANSION OF AUTHORITY TO ISSUE TAXPAYER ASSISTANCE ORDERS.

    (a) TAXPAYER’S HARDSHIP- Section 7811(a) (relating to authority to issue) is amended by striking ‘significant’.

    (b) TERMS OF ORDERS- Subsection (b) of section 7811 (relating to terms of taxpayer assistance orders) is amended--

      (1) by inserting ‘within a specified time period’ after ‘the Secretary’, and

      (2) by inserting ‘take any action as permitted by law,’ after ‘cease any action,’.

    (c) LIMITATION ON AUTHORITY TO MODIFY OR RESCIND- Section 7811(c) (relating to authority to modify or rescind) is amended to read as follows:

    ‘(c) AUTHORITY TO MODIFY OR RESCIND- Any Taxpayer Assistance Order issued by the Taxpayer Advocate under this section may be modified or rescinded only by the Taxpayer Advocate, the Commissioner, or any superior of either.’

    (d) EFFECTIVE DATE- The amendments made by this section shall take effect on the date of the enactment of this Act.

TITLE II--MODIFICATIONS TO INSTALLMENT AGREEMENT PROVISIONS

SEC. 201. TAXPAYER’S RIGHT TO INSTALLMENT AGREEMENT.

    (a) IN GENERAL- Subsection (a) of section 6159 (relating to agreements for payment of tax liability in installments) is amended to read as follows:

    ‘(a) IN GENERAL-

      ‘(1) AUTHORIZATION OF AGREEMENTS- The Secretary is authorized to enter into written agreements with any taxpayer under which such taxpayer is allowed to satisfy liability for payment of any tax in installment payments if the Secretary determines that such agreement will facilitate collection of such liability.

      ‘(2) AGREEMENT AS A MATTER OF RIGHT- In the case of any taxpayer other than a corporation, the Secretary shall enter into such an agreement if--

        ‘(A) the taxpayer requests such an agreement,

        ‘(B) the tax liability is attributable to the tax imposed under chapter 1 and is less than $10,000, and

        ‘(C) the taxpayer has paid any tax liability for the 3 preceding taxable years at the time such liability was due.

      ‘(3) NOTICE- The Secretary shall include in the instructions for returns of the tax imposed under chapter 1 the rights of taxpayers under this subsection and the steps necessary to exercise those rights.’

    (b) EFFECTIVE DATE- The amendment made by subsection (a) shall take effect on the date of the enactment of this Act.

SEC. 202. RUNNING OF FAILURE TO PAY PENALTY SUSPENDED DURING PERIOD INSTALLMENT AGREEMENT IN EFFECT.

    (a) GENERAL RULE- Section 6651 (relating to penalty for failure to file tax return or to pay tax) is amended by adding at the end the following new subsection:

    ‘(g) TREATMENT OF INSTALLMENT AGREEMENTS UNDER SECTION 6159- If--

      ‘(1) an agreement is entered into under section 6159 for the payment of any tax in installments, and

      ‘(2) the taxpayer requested the Secretary to enter into the agreement on or before the due date (including extensions) for the return of the tax,

    the period during which such agreement is in effect shall be disregarded in determining the amount of any addition under paragraph (2) or (3) of subsection (a) with respect to such tax.’

    (b) EFFECTIVE DATE- The amendment made by subsection (a) shall apply to installment agreements entered into after the date of the enactment of this Act.

SEC. 203. NOTIFICATION OF REASONS FOR TERMINATION OR DENIAL OF INSTALLMENT AGREEMENTS.

    (a) TERMINATIONS- Subsection (b) of section 6159 (relating to extent to which agreements remain in effect)

is amended by adding at the end the following new paragraph:

      ‘(5) NOTICE REQUIREMENTS- The Secretary may not take any action under paragraph (2), (3), or (4) unless--

        ‘(A) a notice of such action is provided to the taxpayer not later than the day 30 days before the date of such action, and

        ‘(B) such notice includes an explanation why the Secretary intends to take such action.

      The preceding sentence shall not apply in any case in which the Secretary believes that collection of any tax to which an agreement under this section relates is in jeopardy.’

    (b) DENIALS- Section 6159 (relating to agreements for payment of tax liability in installments) is amended by adding at the end the following new subsection:

    ‘(c) NOTICE REQUIREMENTS FOR DENIALS- The Secretary may not deny any request for an installment agreement under this section unless--

      ‘(1) a notice of the proposed denial is provided to the taxpayer not later than the day 30 days before the date of such denial,

      ‘(2) such notice includes an explanation why the Secretary intends to deny such request, and

      ‘(3) such notice includes a statement of the taxpayer’s right to administrative review under subsection (d).

    The preceding sentence shall not apply in any case in which the Secretary believes that collection of any tax to which a request for an agreement under this section relates is in jeopardy.’

    (c) CONFORMING AMENDMENT- Paragraph (3) of section 6159(b) is amended to read as follows:

      ‘(3) SUBSEQUENT CHANGE IN FINANCIAL CONDITIONS- If the Secretary makes a determination that the financial condition of a taxpayer with whom the Secretary has entered into an agreement under subsection (a) has significantly changed, the Secretary may alter, modify, or terminate such agreement.’

    (d) EFFECTIVE DATE- The amendments made by this section shall take effect on the date 6 months after the date of the enactment of this Act.

SEC. 204. ADMINISTRATIVE REVIEW OF DENIAL OF REQUEST FOR, OR TERMINATION OF, INSTALLMENT AGREEMENT.

    (a) GENERAL RULE- Section 6159 (relating to agreements for payment of tax liability in installments), as amended by section 203(b), is amended by adding at the end the following new subsection:

    ‘(d) ADMINISTRATIVE REVIEW- The Secretary shall establish procedures for an independent administrative review of denials of requests for, or terminations of, installment agreements under this section.’

    (b) EFFECTIVE DATE- The amendment made by subsection (a) shall take effect on January 1, 1996.

TITLE III--INTEREST

SEC. 301. EXPANSION OF AUTHORITY TO ABATE INTEREST.

    (a) GENERAL RULE- Paragraph (1) of section 6404(e) (relating to abatement of interest in certain cases) is amended--

      (1) by inserting ‘unreasonable’ before ‘error’ each place it appears in subparagraphs (A) and (B), and

      (2) by striking ‘in performing a ministerial act’ each place it appears.

    (b) MANDATORY ABATEMENT FOR SMALL TAXPAYERS- The first sentence of section 6404(e)(1) is amended by inserting ‘in the case of a taxpayer not described in section 7430(c)(4)(A)(iii) and shall abate the assessment of such interest until the date demand for payment is made in the case of a taxpayer described in section 7430(c)(4)(A)(iii)’ before the period at the end.

    (c) CLERICAL AMENDMENT- The subsection heading for subsection (e) of section 6404 is amended by striking ‘Assessments’ and inserting ‘Abatement’.

    (d) EFFECTIVE DATE- The amendments made by this section shall apply to interest accruing with respect to deficiencies or payments for taxable years beginning after the date of the enactment of this Act.

SEC. 302. EXTENSION OF INTEREST-FREE PERIOD FOR PAYMENT OF TAX AFTER NOTICE AND DEMAND.

    (a) GENERAL RULE- Paragraph (3) of section 6601(e) (relating to payments made within 10 days after notice and demand) is amended to read as follows:

      ‘(3) PAYMENTS MADE WITHIN SPECIFIED PERIOD AFTER NOTICE AND DEMAND- If notice and demand is made for payment of any amount and if such amount is paid within 21 days (10 days if the amount for which such notice and demand is made equals or exceeds $100,000) after the date of such notice and demand, interest under this section on the amount so paid shall not be imposed for the period after the date of such notice and demand.’

    (b) CONFORMING AMENDMENT- Paragraph (3) of section 6651(a) (relating to addition to tax for failure to file tax return or pay tax) is amended by striking ‘10 days’ and inserting ‘21 days (10 days if the amount for which such notice and demand is made equals or exceeds $100,000)’.

    (c) EFFECTIVE DATE- The amendments made by this section shall apply in the case of any notice and demand given after December 31, 1995.

TITLE IV--JOINT RETURNS

SEC. 401. DISCLOSURE OF COLLECTION ACTIVITIES.

    (a) GENERAL RULE- Subsection (e) of section 6103 (relating to disclosure to persons having material interest) is amended by adding at the end the following new paragraph:

      ‘(8) DISCLOSURE OF COLLECTION ACTIVITIES WITH RESPECT TO JOINT RETURN- If any deficiency of tax with respect to a joint return is assessed and the individuals filing such return are no longer married or no longer reside in the same household, upon request in writing of either of such individuals, the Secretary may disclose in writing to the individual making the request whether the Secretary has attempted to collect such deficiency from such other individual, the general nature of such collection activities, and the amount collected.’

    (b) EFFECTIVE DATE- The amendment made by subsection (a) shall take effect on the date of the enactment of this Act.

SEC. 402. JOINT RETURN MAY BE MADE AFTER SEPARATE RETURNS WITHOUT FULL PAYMENT OF TAX.

    (a) GENERAL RULE- Paragraph (2) of section 6013(b) (relating to limitations on filing of joint return after filing separate returns) is amended by striking subparagraph (A) and redesignating the following subparagraphs accordingly.

    (b) EFFECTIVE DATE- The amendment made by subsection (a) shall apply to taxable years beginning after the date of the enactment of this Act.

TITLE V--COLLECTION ACTIVITIES

SEC. 501. MODIFICATIONS TO LIEN AND LEVY PROVISIONS.

    (a) WITHDRAWAL OF CERTAIN NOTICES- Section 6323 (relating to validity and priority against certain persons) is amended by adding at the end the following new subsection:

    ‘(j) WITHDRAWAL OF NOTICE IN CERTAIN CIRCUMSTANCES-

      ‘(1) IN GENERAL- The Secretary may withdraw a notice of a lien filed under this section and this chapter shall be applied as if the withdrawn notice had not been filed, if the Secretary determines that--

        ‘(A) the filing of such notice was premature or otherwise not in accordance with administrative procedures of the Secretary,

        ‘(B) the taxpayer has entered into an agreement under section 6159 to satisfy the tax liability for which the lien was imposed by means of installment payments, unless such agreement provides otherwise,

        ‘(C) the withdrawal of such notice will facilitate the collection of the tax liability, or

        ‘(D) with the consent of the taxpayer or the Taxpayer Advocate, the withdrawal of such notice would be in the best interests of the taxpayer (as determined by the Taxpayer Advocate) and the United States.

      Any such withdrawal shall be made by filing notice at the same office as the withdrawn notice. A copy of such notice of withdrawal shall be provided to the taxpayer.

      ‘(2) NOTICE TO CREDIT AGENCIES, ETC- Upon written request by the taxpayer with respect to whom a notice of a lien was withdrawn under paragraph (1), the Secretary shall promptly make

reasonable efforts to notify credit reporting agencies, and any financial institution or creditor whose name and address is specified in such request, of the withdrawal of such notice. Any such request shall be in such form as the Secretary may prescribe.’

    (b) RETURN OF LEVIED PROPERTY IN CERTAIN CASES- Section 6343 (relating to authority to release levy and return property) is amended by adding at the end the following new subsection:

    ‘(d) RETURN OF PROPERTY IN CERTAIN CASES- If--

      ‘(1) any property has been levied upon, and

      ‘(2) the Secretary determines that--

        ‘(A) the levy on such property was premature or otherwise not in accordance with administrative procedures of the Secretary,

        ‘(B) the taxpayer has entered into an agreement under section 6159 to satisfy the tax liability for which the levy was imposed by means of installment payments, unless such agreement provides otherwise,

        ‘(C) the return of such property will facilitate the collection of the tax liability, or

        ‘(D) with the consent of the taxpayer or the Taxpayer Advocate, the return of such property would be in the best interests of the taxpayer (as determined by the Taxpayer Advocate) and the United States,

    the provisions of subsection (b) shall apply in the same manner as if such property had been wrongly levied upon, except that no interest shall be allowed under subsection (c).’

    (c) MODIFICATIONS IN CERTAIN LEVY EXEMPTION AMOUNTS-

      (1) FUEL, ETC- Paragraph (2) of section 6334(a) (relating to fuel, provisions, furniture, and personal effects exempt from levy) is amended--

        (A) by striking ‘If the taxpayer is the head of a family, so’ and inserting ‘So’, and

        (B) by striking ‘$1,650 ($1,550 in the case of levies issued during 1989)’ and inserting ‘$1,750’.

      (2) BOOKS, ETC- Paragraph (3) of section 6334(a) (relating to books and tools of a trade, business, or profession exempt from levy) is amended by striking ‘$1,100 ($1,050 in the case of levies issued during 1989)’ and inserting ‘$1,250’.

      (3) INDEXED FOR INFLATION- Section 6334 (relating to property exempt from levy) is amended by adding at the end the following new subsection:

    ‘(f) INFLATION ADJUSTMENTS-

      ‘(1) IN GENERAL- In the case of any calendar year beginning after 1996, each dollar amount referred to in paragraphs (2) and (3) of subsection (a) 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 such calendar year, by substituting ‘calendar year 1995’ for ‘calendar year 1992’ in subparagraph (B) thereof.

      ‘(2) ROUNDING- If any dollar amount after being increased under paragraph (1) is not a multiple of $10, such dollar amount shall be rounded to the nearest multiple of $10 (or, if such dollar amount is a multiple of $5, such dollar amount shall be increased to the next higher multiple of $10).’

    (d) EFFECTIVE DATES-

      (1) IN GENERAL- Except as provided in paragraph (2), the amendments made by this section shall take effect on the date of the enactment of this Act.

      (2) EXEMPT AMOUNTS- The amendments made by subsection (c) shall take effect with respect to levies issued after December 31, 1995.

SEC. 502. OFFERS-IN-COMPROMISE.

    (a) GENERAL RULE- Subsection (a) of section 7122 (relating to compromises) is amended by adding at the end the following new sentence: ‘The Secretary may make such a compromise in any case where the Secretary determines that such compromise would be in the best interests of the United States.’

    (b) REVIEW REQUIREMENTS- Subsection (b) of section 7122 (relating to records) is amended by striking ‘$500.’ and inserting ‘$50,000. However, such compromise shall be subject to continuing quality review by the Secretary.’

    (c) EFFECTIVE DATE- The amendments made by this section shall take effect on the date of the enactment of this Act.

SEC. 503. NOTIFICATION OF EXAMINATION.

    (a) IN GENERAL- Section 7605 (relating to restrictions on examination of taxpayer) is amended by redesignating subsection (c) as subsection (d) and by inserting after subsection (b) the following new subsection:

    ‘(c) NOTIFICATION REQUIREMENT- No examination described in subsection (a) shall be made unless the Secretary notifies the taxpayer in writing by mail to an address determined under section 6212(b) that the taxpayer is under examination and provides the taxpayer with an explanation of the process as described in section

7521(b)(1). The preceding sentence shall not apply in the case of any examination if the Secretary determines that--

      ‘(1) such examination is in connection with a criminal investigation or is with respect to a tax the collection of which is in jeopardy, or

      ‘(2) the application of the preceding sentence would be inconsistent with national security needs or would interfere with the effective conduct of a confidential law enforcement or foreign counterintelligence activity.’

    (b) CONFORMING AMENDMENT- Paragraph (1) of section 7521(b) (relating to safeguards) is amended by striking ‘or at’.

    (c) EFFECTIVE DATE- The amendments made by this section shall take effect on the date of the enactment of this Act.

SEC. 504. INCREASE IN LIMIT ON RECOVERY OF CIVIL DAMAGES FOR UNAUTHORIZED COLLECTION ACTIONS.

    (a) GENERAL RULE- Subsection (b) of section 7433 (relating to damages) is amended by striking ‘$100,000’ and inserting ‘$1,000,000’.

    (b) EFFECTIVE DATE- The amendment made by subsection (a) shall apply to actions by officers or employees of the Internal Revenue Service after the date of the enactment of this Act.

SEC. 505. SAFEGUARDS RELATING TO DESIGNATED SUMMONS.

    (a) STANDARD OF REVIEW- Subparagraph (A) of section 6503(k)(2) (defining designated summons) is amended by redesignating clauses (i) and (ii) as clauses (ii) and (iii), respectively, and by inserting before clause (ii) (as so redesignated) the following new clause:

          ‘(i) the issuance of such summons is preceded by a review of such issuance by the regional counsel of the Office of Chief Counsel for the region in which the examination of the corporation is being conducted,’.

    (b) NOTICE REQUIREMENTS FOR ISSUANCE- Section 6503(k) is amended by adding at the end the following new paragraph:

      ‘(4) NOTICE REQUIREMENTS- With respect to any summons referred to in paragraph (1)(A) issued to any person other than the corporation, the Secretary shall promptly notify the corporation, in writing, that such summons has been issued with respect to such corporation’s return of tax.’

    (c) EFFECTIVE DATE- The amendments made by this section shall apply to summons issued after the date of the enactment of this Act.

TITLE VI--INFORMATION RETURNS

SEC. 601. PHONE NUMBER OF PERSON PROVIDING PAYEE STATEMENTS REQUIRED TO BE SHOWN ON SUCH STATEMENT.

    (a) GENERAL RULE- The following provisions are each amended by striking ‘name and address’ and inserting ‘name, address, and phone number of the information contact’:

      (1) Section 6041(d)(1).

      (2) Section 6041A(e)(1).

      (3) Section 6042(c)(1).

      (4) Section 6044(e)(1).

      (5) Section 6045(b)(1).

      (6) Section 6049(c)(1)(A).

      (7) Section 6050B(b)(1).

      (8) Section 6050H(d)(1).

      (9) Section 6050I(e)(1).

      (10) Section 6050J(e).

      (11) Section 6050K(b)(1).

      (12) Section 6050N(b)(1).

    (b) EFFECTIVE DATE- The amendments made by subsection (a) shall apply to statements required to be furnished after December 31, 1995 (determined without regard to any extension).

SEC. 602. CIVIL DAMAGES FOR FRAUDULENT FILING OF INFORMATION RETURNS.

    (a) GENERAL RULE- Subchapter B of chapter 76 (relating to proceedings by taxpayers and third parties) is amended by redesignating section 7434 as section 7435 and by inserting after section 7433 the following new section:

‘SEC. 7434. CIVIL DAMAGES FOR FRAUDULENT FILING OF INFORMATION RETURNS.

    ‘(a) IN GENERAL- If any person willfully files a false or fraudulent information return with respect to payments purported to be made to any other person, such other person may bring a civil action for damages against the person so filing such return.

    ‘(b) DAMAGES- In any action brought under subsection (a), upon a finding of liability on the part of the defendant, the defendant shall be liable to the plaintiff in an amount equal to the greater of $5,000 or the sum of--

      ‘(1) any actual damages sustained by the plaintiff as a proximate result of the filing of the false or fraudulent information return (including any costs attributable to resolving deficiencies asserted as a result of such filing), and

      ‘(2) the costs of the action.

    ‘(c) PERIOD FOR BRINGING ACTION- Notwithstanding any other provision of law, an action to enforce the liability created under this section may be brought without regard to the amount in controversy and may be brought only within the later of--

      ‘(1) 6 years after the date of the filing of the false or fraudulent information return, or

      ‘(2) 1 year after the date such false or fraudulent information return would have been discovered by exercise of reasonable care.

    ‘(d) COPY OF COMPLAINT FILED WITH IRS- Any person bringing an action under subsection (a) shall provide a copy of the complaint to the Internal Revenue Service upon the filing of such complaint with the court.

    ‘(e) FINDING OF COURT TO INCLUDE CORRECT AMOUNT OF PAYMENT- The judgment of the court in an action brought under subsection (a) shall include a finding of the correct amount which should have been reported in the information return.

    ‘(f) INFORMATION RETURN- For purposes of this section, the term ‘information return’ means any statement described in section 6724(d)(1)(A).’

    (b) CLERICAL AMENDMENT- The table of sections for subchapter B of chapter 76 is amended by striking the item relating to section 7434 and inserting the following:

‘Sec. 7434. Civil damages for fraudulent filing of information returns.

‘Sec. 7435. Cross references.’

    (c) EFFECTIVE DATE- The amendments made by this section shall apply to false or fraudulent information returns filed after the date of the enactment of this Act.

SEC. 603. REQUIREMENT TO CONDUCT REASONABLE INVESTIGATIONS OF INFORMATION RETURNS.

    (a) GENERAL RULE- Section 6201 (relating to assessment authority) is amended by redesignating subsection (d) as subsection (e) and by inserting after subsection (c) the following new subsection:

    ‘(d) REQUIRED REASONABLE INVESTIGATION OF INFORMATION RETURNS- If a taxpayer asserts a reasonable dispute with respect to any item of income reported on an information return filed with the Secretary under chapter 61 by a third party, the Secretary, when making a determination of a deficiency based on such information return, shall have the burden of proof with respect to such determination unless the Secretary has conducted a reasonable investigation to corroborate the accuracy of such information return.’

    (b) EFFECTIVE DATE- The amendment made by subsection (a) shall take effect on the date of the enactment of this Act.

TITLE VII--MODIFICATIONS TO PENALTY FOR FAILURE TO COLLECT AND PAY OVER TAX

SEC. 701. PRELIMINARY NOTICE REQUIREMENT.

    (a) IN GENERAL- Section 6672 (relating to failure to collect and pay over tax, or attempt to evade or defeat tax) is amended by redesignating subsection (b) as subsection (c) and by inserting after subsection (a) the following new subsection:

    ‘(b) PRELIMINARY NOTICE REQUIREMENT-

      ‘(1) IN GENERAL- No penalty shall be imposed under subsection (a) unless the Secretary notifies the taxpayer in writing by mail to an address as determined under section 6212(b) that the taxpayer shall be subject to an assessment of such penalty.

      ‘(2) TIMING OF NOTICE- The mailing of the notice described in paragraph (1) shall precede any notice and demand of any penalty under subsection (a) by at least 60 days.

      ‘(3) STATUTE OF LIMITATIONS- If a notice described in paragraph (1) with respect to any penalty is mailed before the expiration of the period provided by section 6501 for the assessment of such penalty (determined without regard to this paragraph), the period provided by such section for the assessment of such penalty shall not expire before the date 90 days after the date on which such notice was mailed.

      ‘(4) EXCEPTION FOR JEOPARDY- This subsection shall not apply if the Secretary finds that the collection of the penalty is in jeopardy.’

    (b) EFFECTIVE DATE- The amendment made by subsection (a) shall apply to assessments made after June 30, 1994.

SEC. 702. DISCLOSURE OF CERTAIN INFORMATION WHERE MORE THAN 1 PERSON SUBJECT TO PENALTY.

    (a) IN GENERAL- Subsection (e) of section 6103 (relating to disclosure to persons having material interest), as amended by section 401(a), is amended by adding at the end the following new paragraph:

      ‘(9) DISCLOSURE OF CERTAIN INFORMATION WHERE MORE THAN 1 PERSON SUBJECT TO PENALTY UNDER SECTION 6672- If the Secretary determines that a person is liable for a penalty under section 6672(a) with respect to any failure, upon request in writing of such person, the Secretary shall disclose in writing to such person--

        ‘(A) the name of any other person whom the Secretary has determined to be liable for such penalty with respect to such failure, and

        ‘(B) whether the Secretary has attempted to collect such penalty from such other person, the general nature of such collection activities, and the amount collected.’

    (b) EFFECTIVE DATE- The amendment made by subsection (a) shall take effect on the date of the enactment of this Act.

SEC. 703. PENALTIES UNDER SECTION 6672.

    (a) PUBLIC INFORMATION REQUIREMENTS- The Secretary of the Treasury or the Secretary’s delegate (hereafter in this section referred to as the ‘Secretary’) shall take such actions as may be appropriate to ensure that employees are aware of their responsibilities under the Federal tax depository system, the circumstances under which employees may be liable for the penalty imposed by section 6672 of the Internal Revenue Code of 1986, and the responsibility to promptly report to the Internal Revenue Service any failure referred to in subsection (a) of such section 6672. Such actions shall include--

      (1) printing of a warning on deposit coupon booklets and the appropriate tax returns that certain employees may be liable for the penalty imposed by such section 6672, and

      (2) the development of a special information packet.

    (b) BOARD MEMBERS OF TAX-EXEMPT ORGANIZATIONS-

      (1) VOLUNTARY BOARD MEMBERS-

        (A) IN GENERAL- The penalty under section 6672 of the Internal Revenue Code of 1986 shall not be imposed on unpaid, volunteer members of any board of trustees or directors of an organization referred to in section 501 of such Code to the extent such members are solely serving in an honorary capacity, do not participate in the day-to-day or financial operations of the organization, and do not have actual knowledge of the failure on which such penalty is imposed.

        (B) APPLICATION OF PARAGRAPH- This paragraph shall not apply if it results in no person being held liable for the penalty described in section 6672(a) of the Internal Revenue Code of 1986.

      (2) DEVELOPMENT OF EXPLANATORY MATERIALS- The Secretary shall develop materials explaining the circumstances under which board members of tax-exempt organizations (including voluntary and honorary members) may be subject to penalty under section 6672 of such Code. Such materials shall be made available to tax-exempt organizations.

      (3) IRS INSTRUCTIONS- The Secretary shall clarify the instructions to Internal Revenue Service employees on the application of the penalty under section 6672 of such Code with regard to voluntary members of boards of trustees or directors of tax- exempt organizations.

    (c) PROMPT NOTIFICATION- To the maximum extent practicable, the Secretary shall notify all persons who have failed to make timely and complete deposit of any taxes described in section 6672 of the Internal Revenue Code of 1986 of such failure within 30 days after the return was filed reflecting such failure or after the date on which the Secretary is first aware of such failure. If the person failing to make the deposit is not an individual, the Secretary shall notify the entity subject to such deposit requirement and that entity shall notify, within 15 days of the notification by the Secretary, all officers, general partners, trustees, or other managers of the failure.

TITLE VIII--AWARDING OF COSTS AND CERTAIN FEES

SEC. 801. MOTION FOR DISCLOSURE OF INFORMATION.

    Paragraph (4) of section 7430(c) (defining prevailing party) is amended by adding at the end the following new subparagraph:

        ‘(C) MOTION FOR DISCLOSURE OF INFORMATION- Once a taxpayer substantially prevails as described in subparagraph (A)(ii), the taxpayer may file a motion for an order requiring the disclosure (within a reasonable period of time specified by the court) of all information and copies of relevant records in the possession of the Internal Revenue Service with respect to such taxpayer’s case and the substantial justification for the position taken by the Internal Revenue Service.’

SEC. 802. INCREASED LIMIT ON ATTORNEY FEES.

    Paragraph (1) of section 7430(c) (defining reasonable litigation costs) is amended--

      (1) by striking ‘$75’ in clause (iii) of subparagraph (B) and inserting ‘$110’,

      (2) by striking ‘an increase in the cost of living or’ in clause (iii) of subparagraph (B), and

      (3) by adding after clause (iii) the following:

      ‘In the case of any calendar year beginning after 1995, the dollar amount referred to in clause (iii) shall be increased by an amount equal to such dollar amount multiplied by the cost-of-living adjustment determined under section 1(f)(3) for such calendar year, by substituting ‘calendar year 1994’ for ‘calendar year 1992’ in subparagraph (B) thereof. If any dollar amount after being increased under the preceding sentence is not a multiple of $10, such dollar amount shall be rounded to the nearest multiple of $10 (or, if such dollar amount is a multiple of $5, such dollar amount shall be increased to the next higher multiple of $10).’

SEC. 803. FAILURE TO AGREE TO EXTENSION NOT TAKEN INTO ACCOUNT.

    Paragraph (1) of section 7430(b) (relating to requirement that administrative remedies be exhausted) is amended by adding at the end the following new sentence: ‘Any failure to agree to an extension of the time for the assessment of any tax shall not be taken into account for purposes of determining whether the prevailing party meets the requirements of the preceding sentence.’

SEC. 804. AUTHORITY FOR COURT TO AWARD REASONABLE ADMINISTRATIVE COSTS.

    Section 7430(c)(7)(B) is amended to read as follows:

        ‘(B) the position taken in an administrative proceeding to which subsection (a) applies.’

SEC. 805. EFFECTIVE DATE.

    The amendments made by this title shall apply in the case of proceedings commenced after the date of the enactment of this Act.

TITLE IX--OTHER PROVISIONS

SEC. 901. REQUIRED CONTENT OF CERTAIN NOTICES.

    (a) GENERAL RULE- Subsection (a) of section 7522 (relating to content of tax due, deficiency, and other notices) is amended by striking ‘shall describe the basis for, and identify’ and inserting ‘shall set forth the adjustments which are the basis for, and shall identify’.

    (b) EFFECTIVE DATE- The amendment made by subsection (a) shall apply to notices sent after the date 6 months after the date of the enactment of this Act.

SEC. 902. TREATMENT OF SUBSTITUTE RETURNS UNDER SECTION 6651.

    (a) GENERAL RULE- Section 6651 (relating to failure to file tax return or to pay tax), as amended by section 202(a), is amended by adding at the end the following new subsection:

    ‘(h) TREATMENT OF RETURNS PREPARED BY SECRETARY UNDER SECTION 6020(b)- In the case of any return made by the Secretary under section 6020(b)--

      ‘(1) such return shall be disregarded for purposes of determining the amount of the addition under paragraph (1) of subsection (a), but

      ‘(2) such return shall be treated as the return filed by the taxpayer for purposes of determining the amount of the addition under paragraphs (2) and (3) of subsection (a).’

    (b) EFFECTIVE DATE- The amendment made by subsection (a) shall apply in the case of any return the due date for which (determined without regard to extensions) is after the date of the enactment of this Act.

SEC. 903. RELIEF FROM RETROACTIVE APPLICATION OF TREASURY DEPARTMENT REGULATIONS.

    (a) IN GENERAL- Subsection (b) of section 7805 (relating to rules and regulations) is amended to read as follows:

    ‘(b) RETROACTIVITY OF REGULATIONS-

      ‘(1) IN GENERAL- Except as otherwise provided in this subsection, no temporary, proposed, or final regulation relating to the internal revenue laws shall apply to any taxable period ending before the earliest of the following dates:

        ‘(A) The date on which such regulation is filed with the Federal Register.

        ‘(B) In the case of any final regulation, the date on which any proposed or temporary regulation to which such final regulation relates was filed with the Federal Register.

        ‘(C) The date on which any notice substantially describing the expected contents of any temporary, proposed, or final regulation is issued to the public.

      ‘(2) PREVENTION OF ABUSE- The Secretary may provide that any regulation may take effect or apply retroactively to prevent abuse of a statute to which the regulation relates.

      ‘(3) CORRECTION OF PROCEDURAL DEFECTS- The Secretary may provide that any regulation may apply retroactively to correct a procedural defect in the issuance of any prior regulation.

      ‘(4) INTERNAL REGULATIONS- The limitation of paragraph (1) shall not apply to any regulation relating to internal Treasury Department policies, practices, or procedures.

      ‘(5) CONGRESSIONAL AUTHORIZATION- The limitation of paragraph (1) may be superseded by a legislative grant from Congress authorizing the Secretary to prescribe the effective date with respect to any regulation.

      ‘(6) ELECTION TO APPLY RETROACTIVELY- The Secretary may provide for any taxpayer to elect to apply any regulation before the dates specified in paragraph (1).

      ‘(7) APPLICATION TO RULINGS- The Secretary may prescribe the extent, if any, to which any ruling (including any judicial decision or any administrative determination other than by regulation) relating to the internal revenue laws shall be applied without retroactive effect.’

    (b) EFFECTIVE DATE-

      (1) IN GENERAL- Except as provided in paragraph (2), the amendment made by subsection (a) shall apply with respect to--

        (A) any temporary or proposed regulation filed on or after January 5, 1993, and

        (B) any temporary or proposed regulation filed before January 5, 1993, and filed as a final regulation after such date.

      (2) SPECIAL RULE- Section 7805(b)(2) of the Internal Revenue Code of 1986 (as added by subsection (a)) shall apply only to statutes enacted on or after the date of the enactment of this Act.

SEC. 904. REQUIRED NOTICE OF CERTAIN PAYMENTS.

    If any payment is received by the Secretary of the Treasury or the Secretary’s delegate (hereafter in this section referred to as the ‘Secretary’) from any taxpayer and the Secretary cannot associate such payment with any outstanding tax liability of such taxpayer, the Secretary shall make reasonable efforts to notify the taxpayer of such inability within 60 days after the receipt of such payment.

SEC. 905. UNAUTHORIZED ENTICEMENT OF INFORMATION DISCLOSURE.

    (a) IN GENERAL- Subchapter B of chapter 76 (relating to proceedings by taxpayers and third parties), as amended by section 602(a), is amended by redesignating section 7435 as section 7436 and by inserting after section 7434 the following new section:

‘SEC. 7435. CIVIL DAMAGES FOR UNAUTHORIZED ENTICEMENT OF INFORMATION DISCLOSURE.

    ‘(a) IN GENERAL- If any officer or employee of the United States intentionally compromises the determination or collection of any tax due from an attorney, certified public accountant, or enrolled agent representing a taxpayer in exchange for information conveyed by the taxpayer to the attorney, certified public accountant, or enrolled agent for purposes of obtaining advice concerning the taxpayer’s tax liability, such taxpayer may bring a civil action for damages against the United States in a district court of the United States. Such civil action shall be the exclusive remedy for recovering damages resulting from such actions.

    ‘(b) DAMAGES- In any action brought under subsection (a), upon a finding of liability on the part of the defendant, the defendant shall be liable to the plaintiff in an amount equal to the lesser of $500,000 or the sum of--

      ‘(1) actual, direct economic damages sustained by the plaintiff as a proximate result of the information disclosure, and

      ‘(2) the costs of the action.

    Damages shall not include the taxpayer’s liability for any civil or criminal penalties, or other losses attributable to incarceration or the imposition of other criminal sanctions.

    ‘(c) PAYMENT AUTHORITY- Claims pursuant to this section shall be payable out of funds appropriated under section 1304 of title 31, United States Code.

    ‘(d) PERIOD FOR BRINGING ACTION- Notwithstanding any other provision of law, an action to enforce liability created under this section may be brought without regard to the amount in controversy and may be brought only within 2 years after the date the actions creating such liability would have been discovered by exercise of reasonable care.

    ‘(e) MANDATORY STAY- Upon a certification by the Commissioner or the Commissioner’s delegate that there is an ongoing investigation or prosecution of the taxpayer, the district court before which an action under this section is pending, shall stay all proceedings with respect to such action pending the conclusion of the investigation or prosecution.

    ‘(f) CRIME-FRAUD EXCEPTION- Subsection (a) shall not apply to information conveyed to an attorney, certified public accountant, or enrolled agent for the purpose of perpetrating a fraud or crime.’

    (b) CLERICAL AMENDMENT- The table of sections for subchapter B of chapter 76, as amended by section 602(b), is amended by striking the item relating to section 7435 and by adding at the end the following new items:

‘Sec. 7435. Civil damages for unauthorized enticement of information disclosure.

‘Sec. 7436. Cross references.’

    (c) EFFECTIVE DATE- The amendments made by this section shall apply to actions after the date of the enactment of this Act.

TITLE X--FORM MODIFICATIONS; STUDIES

SEC. 1000. DEFINITIONS.

    For purposes of this title:

      (1) SECRETARY- The term ‘Secretary’ means the Secretary of the Treasury or his delegate.

      (2) 1986 CODE- The term ‘1986 Code’ means the Internal Revenue Code of 1986.

      (3) TAX-WRITING COMMITTEES- The term ‘tax-writing Committees’ means the Committee on Ways and Means of the House of Representatives and the Committee on Finance of the Senate.

Subtitle A--Form Modifications

SEC. 1001. EXPLANATION OF CERTAIN PROVISIONS.

    (a) GENERAL RULE- The Secretary shall take such actions as may be appropriate to ensure that taxpayers are aware of the provisions of the 1986 Code permitting payment of tax in installments, extensions of time for payment of tax, and compromises of tax liability. Such actions shall include revising the instructions for filing income tax returns so that such instructions include an explanation of--

      (1) the procedures for requesting the benefits of such provisions, and

      (2) the terms and conditions under which the benefits of such provisions are available.

    (b) COLLECTION NOTICES- In any notice of an underpayment of tax or proposed underpayment of tax sent by the Secretary to any taxpayer, the Secretary shall

include a notification of the availability of the provisions of sections 6159, 6161, and 7122 of the 1986 Code.

SEC. 1002. IMPROVED PROCEDURES FOR NOTIFYING SERVICE OF CHANGE OF ADDRESS OR NAME.

    The Secretary shall provide improved procedures for taxpayers to notify the Secretary of changes in names and addresses. Not later than June 30, 1996, the Secretary shall institute procedures for timely updating all Internal Revenue Service records with change-of-address information provided to the Secretary by taxpayers.

SEC. 1003. RIGHTS AND RESPONSIBILITIES OF DIVORCED INDIVIDUALS.

    The Secretary shall include in the Internal Revenue Service publication entitled ‘Your Rights As A Taxpayer’ a section on the rights and responsibilities of divorced individuals.

Subtitle B--Studies

SEC. 1011. PILOT PROGRAM FOR APPEAL OF ENFORCEMENT ACTIONS.

    (a) GENERAL RULE- The Secretary shall establish a 1-year pilot program for appeals of enforcement actions (including lien, levy, and seizure actions) to the Appeals Division of the Internal Revenue Service--

      (1) where the deficiency was assessed without actual knowledge of the taxpayer,

      (2) where the deficiency was assessed without an opportunity for administrative appeal, and

      (3) in other appropriate circumstances.

    (b) REPORT- Not later than June 30, 1996, the Secretary shall submit to the tax-writing Committees a report on the pilot program established under subsection (a), together with such recommendations as he may deem advisable.

SEC. 1012. STUDY ON TAXPAYERS WITH SPECIAL NEEDS.

    (a) GENERAL RULE- The Secretary shall conduct a study on ways to assist the elderly, physically impaired, foreign-language speaking, and other taxpayers with special needs to comply with the internal revenue laws.

    (b) REPORT- Not later than June 30, 1996, the Secretary shall submit to the tax-writing Committees a report on the study conducted under subsection (a), together with such recommendations as he may deem advisable.

SEC. 1013. REPORTS ON TAXPAYER-RIGHTS EDUCATION PROGRAM.

    Not later than April 1, 1996, the Secretary shall submit a report to the tax-writing Committees on the scope and content of the Internal Revenue Service’s taxpayer-rights education program for its officers and employees. Not later than June 30, 1996, the Secretary shall submit a report to the tax-writing Committees on the effectiveness of the program referred to in the preceding sentence.

SEC. 1014. BIENNIAL REPORTS ON MISCONDUCT BY INTERNAL REVENUE SERVICE EMPLOYEES.

    Not later than June 30, 1996, and during June of each second calendar year thereafter, the Secretary shall report to the tax-writing Committees on all cases involving complaints about misconduct of Internal Revenue Service employees and the disposition of such complaints.

SEC. 1015. STUDY OF NOTICES OF DEFICIENCY.

    (a) GENERAL RULE- The Comptroller General shall conduct a study on--

      (1) the effectiveness of current Internal Revenue Service efforts to notify taxpayers with regard to tax deficiencies under section 6212 of the 1986 Code,

      (2) the number of registered or certified letters and other notices returned to the Internal Revenue Service as undeliverable,

      (3) any followup action taken by the Internal Revenue Service to locate taxpayers who did not receive actual notice,

      (4) the effect that failures to receive notice of such deficiencies have on taxpayers, and

      (5) recommendations to improve Internal Revenue Service notification of taxpayers.

    (b) REPORT- Not later than June 30, 1996, the Comptroller General shall submit to the tax-writing Committees a report on the study conducted under subsection (a), together with such recommendations as he may deem advisable.

SEC. 1016. NOTICE AND FORM ACCURACY STUDY.

    (a) GENERAL RULE- The Comptroller General shall conduct annual studies of the accuracy of 25 of the most commonly used Internal Revenue Service forms, notices, and publications. In conducting any such study, the Comptroller General shall examine the suitability and usefulness of Internal Revenue Service telephone numbers on Internal Revenue Service notices and shall solicit and consider the comments of organizations representing taxpayers, employers, and tax professionals.

    (b) REPORTS- The Comptroller General shall submit to the tax-writing Committees a report on each study conducted under subsection (a), together with such recommendations as he may deem advisable. The first such report shall be submitted not later than June 30, 1996.