S. 4964 Introduced Taxation

Protecting Innocent Taxpayers from Endless Assessments Act

A bill to 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. Introduced
  2. Committee
  3. Passed Senate
  4. Passed House
  5. To President
  6. Became law
Sponsor Sen. Marshall, Roger [R-KS] Introduced July 14, 2026 Cosponsors 1 (1 D) Latest action July 14, 2026

Summary

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.

Summary by the Congressional Research Service, Library of Congress.

Congress.gov

Actions

  1. Jul 14, 2026 Read twice and referred to the Committee on Finance.
  2. Jul 14, 2026 Introduced in Senate

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