H.R. 6495 Amendment - Taxpayer Notification and Privacy Act - Third-Party Contact Notice Specificity
Summary
Representative Smith of Missouri offered a substitute amendment to H.R. 6495, titled the Taxpayer Notification and Privacy Act, which would amend section 7602(c) of the Internal Revenue Code of 1986 to require greater specificity in third-party contact notices. The amendment mandates that IRS identify each specific item of information sought from third parties, and provides taxpayers with a minimum 45-day response period before such contact. An exception is carved out for information the Secretary determines is necessary. The amendments apply to notices provided after 12 months following enactment.
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GovPing monitors House Floor Schedule for new government & legislation regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 34 changes logged to date.
What changed
The amendment would fundamentally restructure the procedural requirements for IRS third-party contact notices under section 7602(c) of the Internal Revenue Code. Taxpayers would receive advance notice identifying each specific item of information the IRS intends to seek from third parties, and would be entitled to a minimum 45-day period to respond before contact occurs. The amendment also creates an exception allowing the Secretary to bypass these specificity requirements when determined necessary.
Affected parties include the Internal Revenue Service, which would need to revise notice templates and procedures, and taxpayers subject to examination, who would gain stronger procedural protections and additional time to respond to inquiries. Tax practitioners and tax controversy professionals should monitor this legislation as it would create new procedural rights in IRS examinations.
Archived snapshot
Apr 27, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
N S AMENDMENT IN THEOATURE OF A GUBSTITUTE H.R. 6495 TO M. S M FFERED BYRMITH OF ISSOURI Strike all after the enacting clause and insert the following:
SECTION 1. SHORT TITLE. 1
This Act may be cited as the ''Taxpayer Notification 2 and Privacy Act''. 3
SEC. 2. SPECIFICITY OF THIRD-PARTY CONTACT NOTICES. 4
.--Paragraph (1) of section 7602(c) 5(a) INENERAL of the Internal Revenue Code of 1986 is amended-- 6 (1) by striking ''and'' at the end of subpara-7 graph (A), 8 (2) by redesignating subparagraph (B) as sub-9 paragraph (C), 10 (3) by inserting after subparagraph (A) the fol-11 lowing new subparagraph: 12 ''(B) in any case in which the information 13 sought to be obtained from such other persons 14 is related to determining tax liability, has not 15 been previously requested from the taxpayer, 16 and could reasonably be provided by the tax-17 payer, identifies each specific item of informa-18
tion intended to be sought from such persons, 1 and'', and 2 (4) by amending subparagraph (C), as redesig-3 nated by paragraph (2), to read as follows: 4 ''(C) except as otherwise provided by the 5 Secretary, provides the taxpayer with reason-6 able opportunity (including, in any case to 7 which subparagraph (B) applies, by providing 8 the information described in such subpara-9 graph) and a period of not less than 45 days 10 (or more, if the taxpayer requests additional 11 time and shows reasonable cause) to respond 12 before contact is made with such other per-13 sons.''. 14 .--Section 7602(c)(3) of the Internal 15(b) EXCEPTION Revenue Code of 1986 is amended-- 16 (1) by redesignating subparagraphs (A), (B), 17 and (C) as clauses (i), (ii), and (iii), respectively, 18 and by moving such clauses 2 ems to the right, 19 .--This sub-20(2) by striking ''E XCEPTIONS .-- 21section'' and inserting ''E XCEPTIONS .--This subsection'', and 22 ''(A) I N GENERAL (3) by adding at the end the following new sub-23 paragraph: 24
-1''(B) EDXCEPTION FOR INFORMATION SPEC .--Subparagraph (B) of paragraph (1) 2IFICITY (and so much of subparagraph (C) of para-3 graph (1) as relates to such subparagraph (B)) 4 shall not apply to information sought from a 5 person other than the taxpayer if the Secretary 6 determines that such information is nec-7 essary.''. 8 .--The amendments made by 9(c) EFFECTIVEATE this section shall apply to notices provided under section 10 7602(c) of the Internal Revenue Code of 1986 after the 11 date that is 12 months after the date of the enactment 12 of this Act. 13
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