Protecting Innocent Taxpayers from Endless Assessments Act

Roger Marshall

Republican · KS · Senator

Source: Congress.gov · FEC

• Peter Welch (D-VT)Original· 2026-07-14

Read twice and referred to the Committee on Finance.

2026-07-14

Source: Congress.gov

Protecting Innocent Taxpayers from Endless Assessments Act This bill limits the amount of time the Internal Revenue Service (IRS) has to assess taxes related to fraudulent or false federal tax returns where there is no intent by the taxpayer to evade taxes. As background, the IRS generally has three years from the date that a tax return is filed (statute of limitations) to assess taxes owed by the taxpayer for the tax year. However, if a false or fraudulent tax return is filed with the intent to evade tax (fraud exception), then the IRS may assess taxes at any time. In Murrin v. Commissioner the U.S. Tax Court held (and the U.S. Court of Appeals for the Third Circuit affirmed) that the fraud exception applies when a tax return preparer places false or fraudulent entries on a tax return without the taxpayer’s knowledge. In contrast, the U.S. Court of Federal Claims held in BASR Partnership v. Commissioner that the fraud exception only applies if the taxpayer intends to evade taxes. The bill limits the fraud exception to cases in which the taxpayer intends to evade taxes.

Plain-English rewrite of the Congressional Research Service summary published on Congress.gov. Cached and reviewed.

119 S4964 IS: Protecting Innocent Taxpayers from Endless Assessments Act U.S. Senate 2026-07-14 text/xml EN Pursuant to Title 17 Section 105 of the United States Code, this file is not subject to copyright protection and is in the public domain. II119th CONGRESS2d SessionS. 4964IN THE SENATE OF THE UNITED STATESJuly 14, 2026Mr. Marshall (for himself and Mr. Welch) introduced the following bill; which was read twice and referred to the Committee on FinanceA BILLTo 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.1.Short titleThis Act may be cited as the Protecting Innocent Taxpayers from Endless Assessments Act.2.Limitation period not extended for victims of preparer fraud(a)In generalSection 6501(c)(1) of the Internal Revenue Code of 1986 is amended by inserting by the taxpayer after intent.(b)Effective dateThe amendment made by this section shall apply to assessments made or proceedings begun after the date of enactment of this Act.

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