This section covers the technical provisions protecting taxpayer rights.
Burden of Proof
The Act shifts the burden of proof to the IRS in certain court proceedings, provided the taxpayer has maintained records and cooperated with reasonable requests.
Confidentiality
The attorney-client privilege is extended to "Federally Authorized Tax Practitioners" (CPAs and Enrolled Agents) in non-criminal proceedings.
Innocent Spouse Relief
The rules were liberalized to make it easier for a spouse to avoid liability for tax underestimates caused by the other spouse (e.g., unreported income the innocent spouse didn't know about).
Collections
- Liens and Levies: The IRS must provide 30 days notice and an opportunity for a hearing before seizing property.
- Seizures: Certain personal property and residences are harder for the IRS to seize.