22. Department of the Treasury · Minor · Needs Congress
Extend the time limit for taxpayers to sue over improper collection actions
Printed page 700 22. Department of the Treasury
“For example, interest on overpayments should be the same as interest on underpayments rather than the government receiving a higher rate, the time limit for taxpayers to sue for damages for improper collection actions should be extended, the jurisdiction of the Tax Court should be expanded, and the tax penalty system should be reformed by rationalizing the penalty structure and reducing some of the most punitive penalties.”
What has happened
- Not started
The two-year limitation period in section 7433(d)(3) for suits for damages for unauthorized collection actions is unchanged. Public Law 119-21 does not amend section 7433, and no enacted law or one-chamber-passed bill extends the period. H.R. 6506, the Taxpayer Due Process Enhancement Act, which passed the House on 2026-05-19, suspends the section 6511 limitations period for refund claims during a collection due process hearing — a different limitation period on a different cause of action.
No action found yet. This entry is the starting point, not a finding.
Research log
What was searched, and what didn’t count as evidence
Research notes
The H.R. 6506 distinction is the playbook’s H.R. 1570 trap in miniature: the bill’s subject is limitation periods in collection proceedings, its title reads like taxpayer due process, and its operative text touches sections 6330, 6402, 6511 and 6330(d) — never section 7433. Its section 4 does expand Tax Court jurisdiction, which is why it is Evidence for #1954 and not for this item.
Shares the cluster negative search with #1952, #1954 and #1955.
- Action
- expand
- Object
- statute of limitations for taxpayer damages suits
- ID
- 1953