S. 4964: Protecting Innocent Taxpayers from Endless Assessments Act
A Senate bill (S.) in the 119th U.S. Congress.
Overview
| Congress | 119th U.S. Congress (2025–2026) |
|---|---|
| Type | Senate bill (S.) |
| Originating chamber | Senate |
| Introduced | 2026-07-14 |
| Sponsor | Sen. Marshall, Roger [R-KS] |
| Policy area | Taxation |
| Cosponsors | 1 |
| Latest action | 2026-07-14 — Read twice and referred to the Committee on Finance. |
| Last updated | 2026-07-31 |
Summary
Official summary (Introduced in Senate, 2026-07-14):
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.
Cosponsors (1)
| Name | Party / state |
|---|---|
| Peter Welch | D VT (original cosponsor) 2026-07-14 |
Full text & official record
The official bill text, section-by-section summary, amendments, committee reports, and the complete legislative timeline for S. 4964 are published by Congress on congress.gov.
View S. 4964 on congress.gov →
Frequently asked questions
What is S. 4964?
S. 4964 is a Senate bill (S.) introduced in the 119th U.S. Congress, originating in the Senate. Official title: Protecting Innocent Taxpayers from Endless Assessments Act.
Where can I read the full bill text?
The full text, cosponsors, amendments, and legislative status for S. 4964 are available on congress.gov.
Bill data: congress.gov API (official congressional records).