Protecting Innocent Taxpayers from Endless Assessments Act
A bill to amend the Internal Revenue Code of 1986 to clarify that the exception to the general statute of limitations for fraudulent returns applies only when a taxpayer seeks to evade their tax obligations.
The bill, SB4964, proposes to change a specific part of the Internal Revenue Code to make it clearer when the rules about when a taxpayer can be audited for fraudulent returns are applied. Currently, there is some confusion about when these rules can be used, but this bill aims to clarify that they should only apply when someone tries to avoid paying their taxes.
This change would affect taxpayers, tax professionals, and the Internal Revenue Service (IRS). If a taxpayer is found to have intentionally evaded their tax obligations, the IRS will have more clear guidelines on when it can investigate and potentially audit those returns. This could mean more clarity and predictability for taxpayers and the IRS.
SB4964 was introduced on July 14, 2026, and has already been read twice in the Senate. It was then referred to the Committee on Finance, which will review it further. If approved by the committee, it will move to the next stage of the legislative process. This bill is a bipartisan effort, co-sponsored by Democrat Peter Welch and Republican Roger Marshall.
