S. 4964 · Where this bill is now
In committee
Introduced in the Senate, Jul 14, 2026
What this bill does
In plain words · AI-written from the official summaryLimits IRS time to assess fraudulent returns
Right now, the IRS can assess taxes owed by a taxpayer at any time if a tax return is considered fraudulent, even if the taxpayer didn't know about false information on it. This bill would change that rule. It says the IRS can only use the fraud exception—which lets them go beyond the normal three-year deadline—when the taxpayer personally intended to commit fraud.
How it affects you
This mainly affects taxpayers who discover that their tax return preparer or someone else filed false information without their knowledge. Under this bill, the IRS would have a three-year limit to assess taxes in those situations, rather than being able to pursue you indefinitely. It would give you more protection from endless IRS assessments when you weren't the one committing the fraud.
Read the official summary (Introduced in Senate, Jul 14, 2026)
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.
Written by AI (Claude) using only the official summary by the Congressional Research Service, the Library of Congress’s nonpartisan research staff. It can miss nuance, so check the official summary and the bill text for details.
2nd SessionS. 4964
A BILL
Protecting Innocent Taxpayers from Endless Assessments Act
Sponsor: Sen. Roger Marshall (R-KS) · Introduced Jul 14, 2026 · Taxation · 1 version of the text
Sources: Congress.gov actions and votes · bill text from GovInfo · latest official action Jul 14, 2026: “Read twice and referred to the Committee on Finance.”