Refund and abatement of penalties and fines paid by eligible individuals

(a) In general Section 7511 of the Internal Revenue Code of 1986, as added by section 2, is amended by adding at the end the following new subsection: (f) Refund and abatement of penalties and fines paid by eligible individuals with respect to periods prior to date of enactment of this section (1) In general (A) Establishment Not later than January 1, 2027, the Secretary (in consultation with the Secretary of State and the Attorney General) shall establish a program to allow any eligible individual (or the spouse or any dependent (as defined in section 152) of such individual) to apply for a refund or an abatement of any amount described in paragraph (2) (including interest) to the extent such amount was attributable to the applicable period. (B) Identification of individuals Not later than January 1, 2027, the Secretary of State and the Attorney General, acting through the Hostage Recovery Fusion Cell (as described in section 304 of the Robert Levinson Hostage Recovery and Hostage-Taking Accountability Act (22 U.S.C. 1741b)), shall— (i) compile a list, based on such information as is available, of individuals who were eligible individuals during the applicable period, and (ii) provide the list described in clause (i) to the Secretary. (C) Notice For purposes of carrying out the program described in subparagraph (A), the Secretary (in consultation with the Secretary of State and the Attorney General) shall, with respect to any individual identified under subparagraph (B), provide notice to such individual— (i) in the case of an individual who has been released on or before the date of the enactment of this subsection, not later than 90 days after the date of the enactment of this subsection, or (ii) in the case of an individual who is released after the date of the enactment of this subsection, not later than 90 days after the date on which such individual is released, that such individual may be eligible for a refund or an abatement of any amount described in paragraph (2) pursuant to the program described in subparagraph (A). (D) Authorization (i) In general Subject to clause (ii), in the case of any refund described in subparagraph (A), the Secretary shall issue such refund to the eligible individual in the same manner as any refund of an overpayment of tax. (ii) Extension of limitation on time for refund With respect to any refund under subparagraph (A)— (I) the 3-year period of limitation prescribed by section 6511(a) shall be extended until the end of the 1-year period beginning on the date that the notice described in subparagraph (C) is provided to the eligible individual, and (II) any limitation under section 6511(b)(2) shall not apply. (2) Eligible individual For purposes of this subsection, the term eligible individual means any applicable individual who, for any taxable year ending during the applicable period, paid or incurred any interest, penalty, additional amount, or addition to the tax in respect to any tax liability for such year of such individual based on a determination that an act described in section 7508(a)(1) was not performed by the time prescribed therefor (without regard to any extensions). (3) Applicable period For purposes of this subsection, the term applicable period means the period— (A) beginning on January 1, 2021, and (B) ending on the date of the enactment of this subsection.. (b) Effective date The amendment made by this section shall apply to taxable years ending on or before the date of the enactment of this Act.