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House Report 119-427 - TAXPAYER NOTIFICATION AND PRIVACY ACT
[House Report 119-427]
[From the U.S. Government Publishing Office]
119th Congress } { Report
HOUSE OF REPRESENTATIVES
2nd Session } { 119-427
======================================================================
TAXPAYER NOTIFICATION AND PRIVACY ACT
_______
January 7, 2026.--Committed to the Committee of the Whole House on the
State of the Union and ordered to be printed
_______
Mr. Smith of Missouri, from the Committee on Ways and Means, submitted
the following
R E P O R T
[To accompany H.R. 6495]
The Committee on Ways and Means, to whom was referred the
bill (H.R. 6495) to amend the Internal Revenue Code of 1986 to
provide for specific taxpayer notice when information is sought
from third parties, having considered the same, reports
favorably thereon with an amendment and recommends that the
bill as amended do pass.
CONTENTS
Page
I. SUMMARY AND BACKGROUND............................................2
A. Purpose and Summary................................... 2
B. Background and Need for Legislation................... 2
C. Legislative History................................... 3
D. Designated Hearing.................................... 3
II. EXPLANATION OF THE BILL...........................................3
A. Specificity of Third-Party Contact Notices............ 3
B. Explanation of Provisions............................. 5
C. Effective Date........................................ 5
III.VOTE OF COMMITTEE.................................................6
IV. BUDGET EFFECTS OF THE BILL........................................6
A. Committee Estimate of Budgetary Effects............... 6
B. Statement Regarding New Budget Authority and Tax
Expenditures Budget Authority........................ 6
C. Cost Estimate Prepared by the Congressional Budget
Office............................................... 7
V. OTHER MATTERS TO BE DISCUSSED UNDER THE RULES OF THE HOUSE........7
A. Committee Oversight Findings and Recommendations...... 7
B. Statement of General Performance Goals and Objectives. 7
C. Applicability of House Rule XXI, Clause 5(b).......... 7
D. Information Relating to Unfunded Mandates............. 7
E. Congressional Earmarks, Limited Tax Benefits, and
Limited Tariff Benefits.............................. 7
F. Duplication of Federal Programs....................... 8
G. Tax Complexity Analysis............................... 8
VI. CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED.............8
The amendment is as follows:
Strike all after the enacting clause and insert the
following:
SECTION 1. SHORT TITLE.
This Act may be cited as the ``Taxpayer Notification and Privacy
Act''.
SEC. 2. SPECIFICITY OF THIRD-PARTY CONTACT NOTICES.
(a) In General.--Paragraph (1) of section 7602(c) of the Internal
Revenue Code of 1986 is amended--
(1) by striking ``and'' at the end of subparagraph (A),
(2) by redesignating subparagraph (B) as subparagraph (C),
(3) by inserting after subparagraph (A) the following new
subparagraph:
``(B) in any case in which the information sought to
be obtained from such other persons is related to
determining tax liability, has not been previously
requested from the taxpayer, and could reasonably be
provided by the taxpayer, identifies each specific item
of information intended to be sought from such persons,
and'', and
(4) by amending subparagraph (C), as redesignated by
paragraph (2), to read as follows:
``(C) except as otherwise provided by the Secretary,
provides the taxpayer with reasonable opportunity and a
period of not less than 45 days (or more, if the
taxpayer requests additional time and shows reasonable
cause) to respond before contact is made with such
other persons.''.
(b) Exception.--Section 7602(c)(3) of the Internal Revenue Code of
1986 is amended--
(1) by redesignating subparagraphs (A), (B), and (C) as
clauses (i), (ii), and (iii), respectively, and by moving such
clauses 2 ems to the right,
(2) by striking ``Exceptions.--This subsection'' and
inserting ``Exceptions.--
``(A) In general.--This subsection'', and
(3) by adding at the end the following new subparagraph:
``(B) Exception for information specificity.--
Subparagraph (B) of paragraph (1) shall not apply to
information sought from a person other than the
taxpayer if the Secretary determines that such
information is necessary.''.
(c) Effective Date.--The amendments made by this section shall apply
to notices provided under section 7602(c) of the Internal Revenue Code
of 1986 after the date that is 12 months after the date of the
enactment of this Act.
I. SUMMARY AND BACKGROUND
A. Purpose and Summary
The bill, H.R. 6495, the ``Taxpayer Notification and
Privacy Act,'' as amended, was ordered reported by the
Committee on Ways and Means on December 10, 2025.
The bill requires the Internal Revenue Service (IRS), in
certain situations, to provide taxpayers with tailored notices
that identify each specific item of information the IRS plans
to request from a third party. Specificity is required in any
case in which (i) the information to be obtained from third
parties is related to determining tax liability, (ii) the
information could reasonably be provided by the taxpayer, and
(iii) the IRS has not previously requested the information from
the taxpayer.
B. Background and Need for Legislation
The IRS has statutory authority to require the production
of information during the examination of a taxpayer. During an
audit, the IRS can informally request that a taxpayer provide
information necessary to arrive at a fair and accurate audit
adjustment, if any adjustment is warranted. When a taxpayer
decides to not cooperate with such a request, whether by
failing to respond or by providing inadequate or incomplete
responses, the IRS can seek information from other witnesses or
sources by issuing an administrative summons. Under current
law, the IRS is required to notify taxpayers at least 45 days
in advance before contacting third parties, such as banks or
employers, to request information about them. This legislation
creates new protections for taxpayers by requiring more
transparency from the IRS and reducing the need for third-party
inquiries.
This bill requires the IRS to tell taxpayers what
information it plans to request from third parties and identify
which parties it intends to contact and subsequently provides
taxpayers an opportunity to supply the additional requested
information directly from their own records within 45 days,
protecting taxpayers' reputation and eliminating the need for
many third-party contacts entirely.
C. Legislative History
Background
H.R. 6495 was introduced on December 5, 2025, and was
referred to the Committee on Ways and Means.
Committee Hearings
On February 11, 2025, the Committee on Ways and Means
Oversight Subcommittee held a hearing titled, ``IRS Return on
Investment and the Need for Modernization'' to examine the lack
of return on investment from funding provided to the IRS by the
Inflation Reduction Act and the need for information technology
modernization at the agency.
Committee Action
The Committee on Ways and Means marked up H.R. 6495, on
December 10, 2025, and order the bill, as amended, favorably
reported (with a quorum being present).
D. Designated Hearing
Pursuant to clause 3(c)(6) of rule XIII, the following
hearing was used to develop and consider H.R. 6495:
On February 11, 2025, the Committee on Ways and Means
Oversight Subcommittee held a hearing titled, ``IRS Return on
Investment and the Need for Modernization'' to examine the lack
of return on investment from funding provided to the IRS by the
Inflation Reduction Act and the need for information technology
modernization at the agency.
II. EXPLANATION OF THE BILL
A. Specificity of Third-Party Contact Notices
PRESENT LAW
The IRS has broad statutory authority to review books and
records of a taxpayer both in the course of an examination to
determine the correct tax liability and during collection
efforts.\1\ During an audit, the IRS may informally request
that the taxpayer provide additional information necessary to
arrive at a fair and accurate audit adjustment or to identify
sources of collection. Some taxpayers fail to cooperate with
such requests, whether by failing to respond or by providing
inadequate or incomplete responses. In such cases, the IRS may
seek the necessary information from other witnesses or sources.
---------------------------------------------------------------------------
\1\Sec. 7602.
---------------------------------------------------------------------------
In attempting to develop information from other witnesses
or sources, the IRS is required to provide notice to the
taxpayer of its intent to contact persons other than the
taxpayer at least 45 days in advance of the period in which the
IRS intends to make such contact. There is no requirement that
the IRS inform the taxpayer what specific information the IRS
needs before contacting third parties. The notice is required
to specify the period during which the IRS intends to contact a
third party, and that period cannot exceed one year. However,
notices are permitted to be issued to the same taxpayer with
respect to the same tax liability specifying third-party
contact periods that, in the aggregate, exceed one year. A
contact notice may not be issued unless there is a present
intent at the time of issuance to make third-party contacts
during the specified period. This intent can be met on the
basis of the assumption that the information sought to be
obtained will not be obtained by other means before such
contact.\2\ The IRS is required to provide periodically to the
taxpayer a record of third parties contacted. This record is
also required to be provided upon request of the taxpayer. The
third-party contact notice requirement does not apply: if the
matter is a subject of a pending criminal investigation, if the
collection of the tax liability is in jeopardy, if the
Secretary of the Treasury (the ``Secretary'') determines for
good cause shown that disclosure may involve reprisal against
any person, or if the taxpayer authorized the contact.
---------------------------------------------------------------------------
\2\Sec. 7602(c)(1).
---------------------------------------------------------------------------
If the informal attempts to develop information from either
the taxpayer or third-party contacts are not successful, the
IRS may issue an administrative summons for such
information.\3\ When the summons in question is issued to a
third party rather than the taxpayer, the IRS generally must
notify the taxpayer whose liability is the subject of the
inquiry, who may then petition a court to quash the summons.\4\
The rules regarding summonses to third parties include five
exceptions to the requirement of providing notice to the
taxpayer whose taxes are the subject of the request: (1)
summonses issued to the taxpayer herself; (2) a summons to
ascertain whether records exist; (3) summonses issued to
identify the owner of a specified bank account or similar
arrangement; (4) collection-related summonses; and (5) criminal
investigation summonses that are not issued to a third-party
recordkeeper within the meaning of Code section 7603(b).\5\
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\3\Sec. 7602(a)(2).
\4\Sec. 7609(a)(1), (b).
\5\Sec. 7609(c)(2).
---------------------------------------------------------------------------
A request for information in the form of an administrative
summons is enforceable in court if the IRS establishes its good
faith, as evidenced by the factors enunciated by the Supreme
Court in United States v. Powell.\6\ The Court articulated four
basic elements necessary to establish that the government
issued a summons in good faith: (1) The investigation must be
conducted for a legitimate purpose; (2) the information sought
is relevant to and ``may shed light on'' that legitimate
purpose; (3) the requested information is not already in the
possession of the IRS; and (4) the IRS complied with all
statutorily required administrative steps.\7\ Subsequent to
United States v. Powell, the legitimacy of using an
administrative summons in furtherance of an investigation into
criminal violations was validated in United States v. LaSalle
National Bank,\8\ in which the Supreme Court determined that
the dual civil and criminal purpose was legitimate, so long as
there had not yet been a commitment to refer the case for
prosecution.
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\6\United States v. Powell, 379 U.S. 48 (1964).
\7\Ibid. at 57-8.
\8\437 U.S. 298 (1978); codified in section 7609(c).
---------------------------------------------------------------------------
REASONS FOR CHANGE
The Committee believes that requiring a tailored notice
that identifies the specific information the IRS plans to
request from a third party will be more effective in motivating
taxpayers to provide the information themselves. In addition,
the Committee believes that identifying what information the
IRS is seeking empowers the taxpayer to protect their
reputation by providing the information themselves, so that the
third-party contact becomes unnecessary. As a result, using
tailored notices is consistent with a taxpayer's right to be
informed and right to privacy, which includes the right to
enforcement measures that are no more intrusive than necessary.
Finally, the Committee believes that tailored notices are
likely to save IRS resources by reducing the number of third-
party contacts.
B. Explanation of Provisions
With respect to the third-party notice requirements, the
provision requires the IRS, in certain situations, to provide
taxpayers with tailored notices that identify each specific
item of information the IRS plans to request from a third
party.\9\ Specificity is required in any case in which (i) the
information to be obtained from third parties is related to
determining tax liability, (ii) the information could
reasonably be provided by the taxpayer, and (iii) the IRS has
not previously requested the information from the taxpayer.
However, specificity is not required if the Secretary
determines that the information sought from a person other than
the taxpayer is necessary.
---------------------------------------------------------------------------
\9\The provision does not affect the other provisions in Code
section 7602 dealing with third-party summonses.
---------------------------------------------------------------------------
Except as otherwise provided by the Secretary, the
provision requires the notice to provide the taxpayer with at
least 45 days (or more, if the taxpayer requests additional
time and shows reasonable cause) to respond to the notice
before contact is made with a third party.
C. Effective Date
The provision applies to notices provided under Code
section 7602(c) after the date that is 12 months after the date
of enactment.
III. VOTE OF COMMITTEE
In compliance with the Rules of the House of
Representatives, the following statement is made concerning the
vote of the Committee on Ways and Means during the markup
consideration of H.R. 6495, the ``Taxpayer Notification and
Privacy Act,'' on December 10, 2025.
H.R. 6495 was ordered favorably reported to the House of
Representatives as amended by a roll call vote of 41 yeas to 0
nays (with a quorum being present). The vote was as follows:
----------------------------------------------------------------------------------------------------------------
Representative Yea Nay Present Representative Yea Nay Present
----------------------------------------------------------------------------------------------------------------
Mr. Smith (MO)..................... X ...... ......... Mr. Neal............. X ...... .........
Mr. Buchanan....................... X ...... ......... Mr. Doggett.......... X ...... .........
Mr. Smith (NE)..................... X ...... ......... Mr. Thompson......... X ...... .........
Mr. Kelly.......................... X ...... ......... Mr. Larson........... X ...... .........
Mr. Schweikert..................... X ...... ......... Mr. Davis............ X ...... .........
Mr. LaHood......................... X ...... ......... Ms. Sanchez.......... ...... ...... .........
Mr. Arrington...................... X ...... ......... Ms. Sewell........... X ...... .........
Mr. Estes.......................... X ...... ......... Ms. DelBene.......... X ...... .........
Mr. Smucker........................ ...... ...... ......... Ms. Chu.............. X ...... .........
Mr. Hern........................... X ...... ......... Ms. Moore (WI)....... X ...... .........
Mrs. Miller (WV)................... X ...... ......... Mr. Boyle............ X ...... .........
Dr. Murphy......................... X ...... ......... Mr. Beyer............ X ...... .........
Mr. Kustoff........................ X ...... ......... Mr. Evans............ X ...... .........
Mr. Fitzpatrick.................... X ...... ......... Mr. Schneider........ X ...... .........
Mr. Steube......................... X ...... ......... Mr. Panetta.......... X ...... .........
Ms. Tenney......................... X ...... ......... Mr. Gomez............ X ...... .........
Mrs. Fischbach..................... X ...... ......... Mr. Horsford......... X ...... .........
Mr. Moore (UT)..................... X ...... ......... Ms. Plaskett......... ...... ...... .........
Ms. Van Duyne...................... X ...... ......... Mr. Suozzi........... X ...... .........
Mr. Feenstra....................... X ...... .........
Ms. Malliotakis.................... X ...... .........
Mr. Carey.......................... X ...... .........
Mr. Yakym.......................... X ...... .........
Mr. Miller......................... ...... ...... .........
Mr. Bean........................... X ...... .........
Mr. Moran.......................... X ...... .........
----------------------------------------------------------------------------------------------------------------
IV. BUDGET EFFECTS OF THE BILL
A. Committee Estimate of Budgetary Effects
With respect to clause 3(d) of rule XIII of the Rules of
the House of Representatives, the following statement is made
concerning the effects on the budget of the bill, H.R. 6495, as
reported. The estimate prepared by the Congressional Budget
Office is included below.
The staff of the Joint Committee on Taxation estimates that
the bill has a negligible effect on Federal fiscal year budget
receipts.
B. Statement Regarding New Budget Authority and
Tax Expenditures Budget Authority
In compliance with clause 3(c)(2) of rule XIII of the Rules
of the House of Representatives, the Committee states that the
bill involved no new or increased budget authority. The
Committee states further that the bill involves no new or
increased tax expenditures.
C. Cost Estimate Prepared by the
Congressional Budget Office
The Congressional Budget Act of 1974, as amended stipulates
that revenue estimates provided by the staff of the Joint
Committee on Taxation (``JCT'') will be the official estimates
for all tax legislation considered by Congress. As such CBO
incorporates these estimates into its cos estimates of the
effects of the legislation. The estimates for the revenue
provisions of H.R. 6495, as reported were provided by JCT (see
Part IV, A).
V. OTHER MATTERS TO BE DISCUSSED UNDER THE RULES OF THE HOUSE
A. Committee Oversight Findings and Recommendations
With respect to clause 3(c)(1) of rule XIII of the Rules of
the House of Representatives, the Committee made findings and
recommendations that are reflected in this report.
B. Statement of General Performance Goals and Objectives
With respect to clause 3(c)(4) of rule XIII of the Rules of
the House of Representatives, the Committee advises that the
bill does not authorize funding, so no statement of general
performance goals and objectives is required.
C. Applicability of House Rule XXI, Clause 5(b)
Rule XXI 5(b) of the Rules of the House of Representatives
provides, in part, that ``A bill or joint resolution,
amendment, or conference report carrying a Federal income tax
rate increase may not be considered as passed or agreed to
unless so determined by a vote of not less than three-fifths of
the Members voting, a quorum being present.''
The Committee has carefully reviewed the bill, and states
that the bill does not provide such a Federal income tax rate
increase.
D. Information Relating to Unfunded Mandates
This information is provided in accordance with section 423
of the Unfunded Mandates Reform Act of 1995 (Pub. L. No. 104-
4).
The Committee has determined that the bill does not contain
Federal mandates on the private sector. The Committee has
determined that the bill does not impose a Federal
intergovernmental mandate on State, local, or tribal
governments.
E. Congressional Earmarks, Limited Tax Benefits,
and Limited Tariff Benefits
With respect to clause 9 of rule XXI of the Rules of the
House of Representatives, the Committee has carefully reviewed
the provisions of the bill, and states that the provisions of
the bill do not contain any congressional earmarks, limited tax
benefits, or limited tariff benefits within the meaning of the
rule.
F. Duplication of Federal Programs
In compliance with clause 3(c)(5) of rule XIII of the Rules
of the House of Representatives, the Committee states that no
provision of the bill establishes or reauthorizes: (1) a
program of the Federal Government known to be duplicative of
another Federal program; (2) a program included in any report
from the Government Accountability Office to Congress pursuant
to section 21 of Public Law 111-139; or (3) a program related
to a program identified in the most recent Catalog of Federal
Domestic Assistance, published pursuant to the Federal Program
Information Act (Pub. L. No. 95-220, as amended by Pub. L. No.
98-169).
G. Tax Complexity Analysis
Section 4022(b) of the Internal Revenue Service Reform and
Restructuring Act of 1998 (the ``IRS Reform Act'') requires the
staff of the Joint Committee on Taxation (in consultation with
the Internal Revenue Service and the Treasury Department) to
provide a tax complexity analysis. The complexity analysis is
required for all legislation reported by the Senate Committee
on Finance, the House Committee on Ways and Means, or any
committee of conference if the legislation includes a provision
that directly or indirectly amends the Internal Revenue Code
and has widespread applicability to individuals or small
businesses.
The staff of the Joint Committee on Taxation has determined
that there are no provisions that are of widespread
applicability to individuals or small businesses.
VI. CHANGES IN EXISTING LAW MADE BY THE BILL,
AS REPORTED
In compliance with clause 3(e) of rule XIII of the Rules of
the House of Representatives, changes in existing law made by
the bill, as reported, are shown as follows.
Changes in Existing Law Made by the Bill, as Reported
In compliance with clause 3(e) of rule XIII of the Rules of
the House of Representatives, changes in existing law made by
the bill, as reported, are shown as follows (existing law
proposed to be omitted is enclosed in black brackets, new
matter is printed in italics, and existing law in which no
change is proposed is shown in roman):
INTERNAL REVENUE CODE OF 1986
* * * * * * *
Subtitle F--Procedure and Administration
* * * * * * *
CHAPTER 78--DISCOVERY OF LIABILITY AND ENFORCEMENT OF TITLE
Subchapter A--EXAMINATION AND INSPECTION
* * * * * * *
SEC. 7602. EXAMINATION OF BOOKS AND WITNESSES.
(a) Authority to summon, etc..--For the purpose of
ascertaining the correctness of any return, making a return
where none has been made, determining the liability of any
person for any internal revenue tax or the liability at law or
in equity of any transferee or fiduciary of any person in
respect of any internal revenue tax, or collecting any such
liability, the Secretary is authorized--
(1) To examine any books, papers, records, or other
data which may be relevant or material to such inquiry;
(2) To summon the person liable for tax or required
to perform the act, or any officer or employee of such
person, or any person having possession, custody, or
care of books of account containing entries relating to
the business of the person liable for tax or required
to perform the act, or any other person the Secretary
may deem proper, to appear before the Secretary at a
time and place named in the summons and to produce such
books, papers, records, or other data, and to give such
testimony, under oath, as may be relevant or material
to such inquiry; and
(3) To take such testimony of the person concerned,
under oath, as may be relevant or material to such
inquiry.
(b) Purpose may include inquiry into offense.--The purposes
for which the Secretary may take any action described in
paragraph (1), (2), or (3) of subsection (a) include the
purpose of inquiring into any offense connected with the
administration or enforcement of the internal revenue laws.
(c) Notice of contact of third parties.--
(1) General notice.--An officer or employee of the
Internal Revenue Service may not contact any person
other than the taxpayer with respect to the
determination or collection of the tax liability of
such taxpayer unless such contact occurs during a
period (not greater than 1 year) which is specified in
a notice which--
(A) informs the taxpayer that contacts with
persons other than the taxpayer are intended to
be made during such period, [and]
(B) in any case in which the information
sought to be obtained from such other persons
is related to determining tax liability, has
not been previously requested from the
taxpayer, and could reasonably be provided by
the taxpayer, identifies each specific item of
information intended to be sought from such
persons, and
[(B) except as otherwise provided by the
Secretary, is provided to the taxpayer not
later than 45 days before the beginning of such
period.]
(C) except as otherwise provided by the
Secretary, provides the taxpayer with
reasonable opportunity and a period of not less
than 45 days (or more, if the taxpayer requests
additional time and shows reasonable cause) to
respond before contact is made with such other
persons.
Nothing in the preceding sentence shall prevent the
issuance of notices to the same taxpayer with respect
to the same tax liability with periods specified
therein that, in the aggregate, exceed 1 year. A notice
shall not be issued under this paragraph unless there
is an intent at the time such notice is issued to
contact persons other than the taxpayer during the
period specified in such notice. The preceding sentence
shall not prevent the issuance of a notice if the
requirement of such sentence is met on the basis of the
assumption that the information sought to be obtained
by such contact will not be obtained by other means
before such contact.
(2) Notice of specific contacts.--The Secretary shall
periodically provide to a taxpayer a record of persons
contacted during such period by the Secretary with
respect to the determination or collection of the tax
liability of such taxpayer. Such record shall also be
provided upon request of the taxpayer.
(3) Exceptions.--[This subsection]
(A) In general._This subsection shall not
apply--
[(A)] (i) to any contact which the
taxpayer has authorized;
[(B)] (ii) if the Secretary
determines for good cause shown that
such notice would jeopardize collection
of any tax or such notice may involve
reprisal against any person; or
[(C)] (iii) with respect to any
pending criminal investigation.
(B) Exception for information specificity.--
Subparagraph (B) of paragraph (1) shall not
apply to information sought from a person other
than the taxpayer if the Secretary determines
that such information is necessary.
(d) No administrative summons when there is Justice
Department referral.--
(1) Limitation of authority.--No summons may be
issued under this title, and the Secretary may not
begin any action under section 7604 to enforce any
summons, with respect to any person if a Justice
Department referral is in effect with respect to such
person.
(2) Justice Department referral in effect.--For
purposes of this subsection--
(A) In general.--A Justice Department
referral is in effect with respect to any
person if--
(i) the Secretary has recommended to
the Attorney General a grand jury
investigation of, or the criminal
prosecution of, such person for any
offense connected with the
administration or enforcement of the
internal revenue laws, or
(ii) any request is made under
section 6103(h)(3)(B) for the
disclosure of any return or return
information (within the meaning of
section 6103(b)) relating to such
person.
(B) Termination.--A Justice Department
referral shall cease to be in effect with
respect to a person when--
(i) the Attorney General notifies the
Secretary, in writing, that--
(I) he will not prosecute
such person for any offense
connected with the
administration or enforcement
of the internal revenue laws,
(II) he will not authorize a
grand jury investigation of
such person with respect to
such an offense, or
(III) he will discontinue
such a grand jury
investigation,
(ii) a final disposition has been
made of any criminal proceeding
pertaining to the enforcement of the
internal revenue laws which was
instituted by the Attorney General
against such person, or
(iii) the Attorney General notifies
the Secretary, in writing, that he will
not prosecute such person for any
offense connected with the
administration or enforcement of the
internal revenue laws relating to the
request described in subparagraph
(A)(ii).
(3) Taxable years, etc., treated separately.--For
purposes of this subsection, each taxable period (or,
if there is no taxable period, each taxable event) and
each tax imposed by a separate chapter of this title
shall be treated separately.
(e) Limitation on examination on unreported income.--The
Secretary shall not use financial status or economic reality
examination techniques to determine the existence of unreported
income of any taxpayer unless the Secretary has a reasonable
indication that there is a likelihood of such unreported
income.
(f) Limitation on access of persons other than Internal
Revenue Service officers and employees.--The Secretary shall
not, under the authority of section 6103(n), provide any books,
papers, records, or other data obtained pursuant to this
section to any person authorized under section 6103(n), except
when such person requires such information for the sole purpose
of providing expert evaluation and assistance to the Internal
Revenue Service. No person other than an officer or employee of
the Internal Revenue Service or the Office of Chief Counsel
may, on behalf of the Secretary, question a witness under oath
whose testimony was obtained pursuant to this section.
* * * * * * *
[all]