II
119THCONGRESS
1
STSESSION S. 370
To amend the Internal Revenue Code of 1986 to establish tax credits to
encourage individual and corporate taxpayers to contribute to scholar-
ships for students through eligible scholarship-granting organizations and
eligible workforce training organizations, and for other purposes.
IN THE SENATE OF THE UNITED STATES
FEBRUARY3, 2025
Mr. C
RUZ(for himself and Mr. LANKFORD) introduced the following bill;
which was read twice and referred to the Committee on Finance
A BILL
To amend the Internal Revenue Code of 1986 to establish
tax credits to encourage individual and corporate tax-
payers to contribute to scholarships for students through
eligible scholarship-granting organizations and eligible
workforce training organizations, and for other purposes.
Be it enacted by the Senate and House of Representa-1
tives of the United States of America in Congress assembled, 2
SECTION 1. SHORT TITLE. 3
This Act may be cited as the ‘‘Education Freedom 4
Scholarships and Opportunity Act’’. 5
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SEC. 2. PURPOSE. 1
The purpose of this Act is to encourage individual 2
and corporate taxpayers to contribute to scholarships for 3
individual students through eligible scholarship-granting 4
organizations and eligible workforce training organiza-5
tions, as identified by States. 6
TITLE I—AMENDMENTS TO THE 7
INTERNAL REVENUE CODE 8
OF 1986 9
SEC. 101. REFERENCES TO THE INTERNAL REVENUE CODE 10
OF 1986. 11
Except as otherwise expressly provided, whenever in 12
this title an amendment or repeal is expressed in terms 13
of an amendment to, or repeal of, a section or other provi-14
sion, the reference shall be considered to be made to a 15
section or other provision of the Internal Revenue Code 16
of 1986. 17
SEC. 102. TAX CREDITS FOR CONTRIBUTIONS TO ELIGIBLE 18
SCHOLARSHIP-GRANTING ORGANIZATIONS 19
AND ELIGIBLE WORKFORCE TRAINING ORGA-20
NIZATIONS. 21
(a) C
REDIT FORINDIVIDUALS.— 22
(1) I
N GENERAL.—Subpart A of part IV of sub-23
chapter A of chapter 1 is amended by adding after 24
section 25E the following new section: 25
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‘‘SEC. 25F. CONTRIBUTIONS TO ELIGIBLE SCHOLARSHIP- 1
GRANTING ORGANIZATIONS AND ELIGIBLE 2
WORKFORCE TRAINING ORGANIZATIONS. 3
‘‘(a) A
LLOWANCE OFCREDIT.—In the case of an in-4
dividual, there shall be allowed as a credit against the tax 5
imposed by this chapter for the taxable year an amount 6
equal to the sum of any qualified contributions made by 7
the taxpayer during the taxable year. 8
‘‘(b) A
MOUNT OFCREDIT.—The credit allowed under 9
subsection (a) in any taxable year shall not exceed 10 per-10
cent of the taxpayer’s adjusted gross income for the tax-11
able year. 12
‘‘(c) D
EFINITIONS.—For purposes of this section— 13
‘‘(1) Q
UALIFIED CONTRIBUTION .—The term 14
‘qualified contribution’ means a contribution of cash 15
to any eligible scholarship-granting organization or 16
eligible workforce training organization. 17
‘‘(2) Q
UALIFIED EXPENSE.—The term ‘quali-18
fied expense’ means any educational expense that 19
is— 20
‘‘(A) for an individual student’s elementary 21
or secondary education, as recognized by the 22
State, 23
‘‘(B) for the secondary education compo-24
nent of an individual elementary or secondary 25
student’s career and technical education, as de-26
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fined by section 3(5) of the Carl D. Perkins Ca-1
reer and Technical Education Act of 2006 (20 2
U.S.C. 2302(5)), or 3
‘‘(C) for the purpose of providing eligible 4
individual participants with scholarships for 5
secondary or postsecondary vocational education 6
and training, workforce development, or appren-7
ticeship training, including preparation and ex-8
amination costs relating to portable certificates 9
or credentials, or industry recognized certifi-10
cation or credentialing programs. 11
‘‘(3) E
LIGIBLE SCHOLARSHIP-GRANTING ORGA-12
NIZATION.—The term ‘eligible scholarship-granting 13
organization’ means— 14
‘‘(A) an organization that— 15
‘‘(i) is described in section 501(c)(3) 16
and exempt from taxation under section 17
501(a), 18
‘‘(ii) provides qualifying scholarships 19
for qualified expenses to only individual el-20
ementary and secondary students who— 21
‘‘(I) reside in the State in which 22
the eligible scholarship-granting orga-23
nization is recognized, or 24
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‘‘(II) in the case of the Bureau of 1
Indian Education, are members of a 2
federally recognized tribe, 3
‘‘(iii) a State reports to the Secretary 4
of Education as an eligible scholarship- 5
granting organization pursuant to section 6
201(c)(5)(B) of the Education Freedom 7
Scholarships and Opportunity Act, 8
‘‘(iv) allocates at least 90 percent of 9
qualified contributions to qualifying schol-10
arships for qualified expenses, and 11
‘‘(v) provides scholarships to— 12
‘‘(I) more than 1 eligible student, 13
‘‘(II) more than 1 eligible family, 14
and 15
‘‘(III) different eligible students 16
attending more than one education 17
provider, or 18
‘‘(B) an organization that— 19
‘‘(i) is described in section 501(c)(3) 20
and exempt from taxation under section 21
501(a), and 22
‘‘(ii) pursuant to State law, was able, 23
as of the date of the enactment of the 24
Education Freedom Scholarships and Op-25
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portunity Act, to receive contributions that 1
are eligible for a State tax credit if such 2
contributions are used by the organization 3
to provide scholarships to individual ele-4
mentary and secondary students, including 5
scholarships for attending private schools. 6
‘‘(4) E
LIGIBLE WORKFORCE TRAINING ORGANI -7
ZATION.— 8
‘‘(A) I
N GENERAL.—The term ‘eligible 9
workforce training organization’ means any or-10
ganization— 11
‘‘(i) which is— 12
‘‘(I) described in section 13
501(c)(3) and exempt from taxation 14
under section 501(a), and 15
‘‘(II) not a private foundation (as 16
defined in section 509), 17
‘‘(ii) whose purpose is to provide voca-18
tional education and training, workforce 19
development, or apprenticeship training to 20
eligible potential secondary or postsec-21
ondary students, including organizations 22
whose purpose is to provide scholarships 23
for portable certificates or credentials, or 24
industry recognized certifications or 25
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credentialing programs, including prepara-1
tion and examination costs, 2
‘‘(iii) which is in compliance with ap-3
plicable State laws, 4
‘‘(iv) which a State has reported to 5
the Secretary of Education as an eligible 6
workforce training organization pursuant 7
to section 201(c)(5)(B) of the Education 8
Freedom Scholarships and Opportunity 9
Act, and 10
‘‘(v) which satisfies the requirements 11
described in clauses (iv) and (v) of para-12
graph (3)(A). 13
‘‘(B) P
OTENTIAL ELIGIBLE WORKFORCE 14
TRAINING ORGANIZATIONS .—Eligible workforce 15
training organizations may include, but are not 16
limited to, organizations such as the following 17
(provided that such organizations satisfy the re-18
quirements under subparagraph (A)): 19
‘‘(i) Community colleges. 20
‘‘(ii) Workforce training programs (as 21
defined by the applicable State workforce 22
agency). 23
‘‘(iii) Organizations which provide— 24
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‘‘(I) career and technical edu-1
cation, or 2
‘‘(II) training or apprenticeships, 3
including, but not limited to, training 4
or apprenticeships operated by a col-5
lective bargaining organization or that 6
provide industry recognized certifi-7
cations or credentials. 8
‘‘(iv) Community organizations that 9
provide training that results in a certifi-10
cation. 11
‘‘(5) Q
UALIFYING SCHOLARSHIP .—The term 12
‘qualifying scholarship’ means— 13
‘‘(A) a scholarship granted by an eligible 14
scholarship-granting organization to an indi-15
vidual elementary or secondary student, or 16
‘‘(B) a scholarship granted by an eligible 17
workforce training organization as a scholarship 18
to a secondary or postsecondary student for the 19
purpose of vocational education and training, 20
workforce development, obtaining portable cer-21
tificates or credentials, or industry recognized 22
certification or credentialing programs, includ-23
ing preparation and examination costs, 24
under this section. 25
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‘‘(6) STATE.—The term ‘State’ means each of 1
the 50 States, the District of Columbia, the Com-2
monwealth of Puerto Rico, American Samoa, Guam, 3
the Commonwealth of the Northern Mariana Is-4
lands, the United States Virgin Islands, and the De-5
partment of the Interior (acting through the Bureau 6
of Indian Education). 7
‘‘(d) R
ULES OFCONSTRUCTION.— 8
‘‘(1) I
N GENERAL.—A scholarship awarded to a 9
student from the proceeds of a qualified contribution 10
under this section or section 45BB shall not be con-11
sidered assistance to the school, eligible workforce 12
training organization, or other educational provider 13
that enrolls, or provides educational services to, the 14
student or the student’s parents. 15
‘‘(2) N
OT TREATED AS INCOME .—The amount 16
of any such scholarship shall not be treated as in-17
come of the student or their parents for purposes of 18
Federal tax laws or for determining eligibility for 19
any other Federal program. 20
‘‘(3) P
ROHIBITION OF CONTROL OVER NON -21
PUBLIC EDUCATION PROVIDERS .— 22
‘‘(A) Nothing in this Act shall be con-23
strued to permit, allow, encourage, or authorize 24
any Federal control over any aspect of any pri-25
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vate, religious, or home education provider, 1
whether or not a home education provider is 2
treated as a private school or home school 3
under State law. This Act shall not be con-4
strued to exclude private, religious, or home 5
education providers from participation in pro-6
grams or services under this Act. 7
‘‘(B) Nothing in this Act shall be con-8
strued to permit, allow, encourage, or authorize 9
an entity submitting a list of eligible scholar-10
ship-granting organizations or eligible workforce 11
training organizations on behalf of a State to 12
mandate, direct, or control any aspect of a pri-13
vate or home education provider, regardless of 14
whether or not a home education provider is 15
treated as a private school under State law. 16
‘‘(C) No participating State or entity act-17
ing on behalf of a State shall exclude, discrimi-18
nate against, or otherwise disadvantage any 19
education provider with respect to programs or 20
services under this Act based in whole or in 21
part on the provider’s religious education char-22
acter or affiliation, including religiously or mis-23
sion-based policies or practices. 24
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‘‘(4) PARENTAL RIGHTS TO USE SCHOLAR -1
SHIPS.—No participating State or entity acting on 2
behalf of a State shall disfavor or discourage the use 3
of such scholarships for the purchase of elementary 4
and secondary or workforce training education serv-5
ices, including those services provided by private or 6
nonprofit entities, such as faith-based providers. 7
‘‘(5) S
TATE AND LOCAL AUTHORITY .—Nothing 8
in this section or section 45BB shall be construed to 9
modify a State or local government’s authority and 10
responsibility to fund education. 11
‘‘(e) L
IMITATIONS.— 12
‘‘(1) T
AX LIABILITY.—No credit allowed under 13
this section or section 45BB shall exceed the tax-14
payer’s Federal income tax liability for the taxable 15
year. 16
‘‘(2) P
ROHIBITIONS.—A taxpayer is prohibited 17
from selling or transferring any portion of a tax 18
credit allowed under this section or section 45BB. 19
‘‘(3) D
ENIAL OF DOUBLE BENEFIT .—The Sec-20
retary shall prescribe such regulations or other guid-21
ance to ensure that the sum of the tax benefits pro-22
vided by Federal, State, or local law for a qualified 23
contribution receiving a Federal tax credit in any 24
taxable year shall not exceed the sum of the quali-25
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fied contributions made by the taxpayer for the tax-1
able year. 2
‘‘(f) C
ARRYOVER OFCREDIT.—If a tax credit allowed 3
under this section or section 45BB is not fully used within 4
the applicable taxable year because of insufficient tax li-5
ability on the part of the taxpayer, the unused amount 6
may be carried forward for a period not to exceed 5 years. 7
‘‘(g) E
LECTION.—This section shall apply to a tax-8
payer for a taxable year only if the taxpayer elects to have 9
this section apply for such taxable year. 10
‘‘(h) A
LTERNATIVEMINIMUMTAX.—For purposes of 11
calculating the alternative minimum tax under section 55, 12
a taxpayer may use any credit received for a qualified con-13
tribution under this section.’’. 14
(2) C
LERICAL AMENDMENT .—The table of sec-15
tions for subpart A of part IV of subchapter A of 16
chapter 1 of is amended by inserting after the item 17
relating to section 25E the following new item: 18
‘‘Sec. 25F. Contributions to eligible scholarship-granting organizations and eli-
gible workforce training organizations.’’.
(b) CREDIT FORCORPORATIONS.— 19
(1) I
N GENERAL.—Subpart D of part IV of 20
subchapter A of chapter 1 is amended by adding at 21
the end the following new section: 22
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‘‘SEC. 45BB. CONTRIBUTIONS TO ELIGIBLE SCHOLARSHIP- 1
GRANTING ORGANIZATIONS AND ELIGIBLE 2
WORKFORCE TRAINING ORGANIZATIONS. 3
‘‘(a) A
LLOWANCE OFCREDIT.—For purposes of sec-4
tion 38, in the case of a domestic corporation, there shall 5
be allowed as a credit against the tax imposed by this 6
chapter for the taxable year an amount equal to the sum 7
of any qualified contributions (as defined in section 8
25F(c)(1)) made by such corporation taxpayer during the 9
taxable year. 10
‘‘(b) A
MOUNT OFCREDIT.—The credit allowed under 11
subsection (a) for any taxable year shall not exceed 5 per-12
cent of the taxable income (as defined in section 13
170(b)(2)(D)) of the domestic corporation for such taxable 14
year. 15
‘‘(c) A
DDITIONALPROVISIONS.—For purposes of this 16
section, any qualified contributions made by a domestic 17
corporation shall be subject to the provisions of section 18
25F, to the extent applicable. 19
‘‘(d) E
LECTION.—This section shall apply to a tax-20
payer for a taxable year only if the taxpayer elects to have 21
this section apply for such taxable year.’’. 22
(2) C
REDIT PART OF GENERAL BUSINESS 23
CREDIT.—Section 38(b) is amended— 24
(A) by striking ‘‘plus’’ at the end of para-25
graph (40); 26
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(B) by striking the period at the end of 1
paragraph (41) and inserting ‘‘, plus’’; and 2
(C) by adding at the end the following new 3
paragraph: 4
‘‘(42) the credit for qualified contributions de-5
termined under section 45BB(a).’’. 6
(3) C
LERICAL AMENDMENT .—The table of sec-7
tions for subpart D of part IV of subchapter A of 8
chapter 1 is amended by adding at the end the fol-9
lowing new item: 10
‘‘Sec. 45BB. Contributions to eligible scholarship-granting organizations and el-
igible workforce training organizations.’’.
TITLE II—EDUCATION FREEDOM 11
SCHOLARSHIPS AND OPPOR-12
TUNITY ACT WEB PORTAL 13
AND ADMINISTRATION 14
SEC. 201. EDUCATION FREEDOM SCHOLARSHIPS AND OP-15
PORTUNITY ACT WEB PORTAL AND ADMINIS-16
TRATION. 17
(a) I
NGENERAL.—The Secretary of Education shall, 18
in coordination with the Secretary of the Treasury and 19
the Secretary of Labor, establish, host, and maintain a 20
Web portal that— 21
(1) lists all scholarship-granting organizations 22
and workforce training organizations that are eligi-23
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ble under section 25F or 45BB of the Internal Rev-1
enue Code of 1986; 2
(2) enables a taxpayer to make a qualifying 3
contribution to one or more eligible scholarship- 4
granting organizations and eligible workforce train-5
ing organizations and to immediately obtain both a 6
pre-approval of a tax credit for that contribution 7
and a receipt for tax filings; 8
(3) provides information about the tax benefits 9
of the provisions of the Education Freedom Scholar-10
ships and Opportunity Act under the Internal Rev-11
enue Code of 1986; and 12
(4) enables a State to submit and update infor-13
mation about its programs and its eligible scholar-14
ship-granting organizations and eligible workforce 15
training organizations for informational purposes 16
only, including information on— 17
(A) student eligibility; 18
(B) allowable educational expenses; 19
(C) the types of allowable education pro-20
viders; 21
(D) the percentage of funds an organiza-22
tion may use for program administration; and 23
(E) the percentage of total contributions 24
the organization awards in a calendar year. 25
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(b) NONPORTALCONTRIBUTIONS.—A taxpayer may 1
opt to make a contribution directly to an eligible scholar-2
ship-granting organization or an eligible workforce train-3
ing organization, instead of through the Web portal de-4
scribed in subsection (a), provided that the taxpayer, or 5
the eligible scholarship-granting organization or eligible 6
workforce training organization on behalf of the taxpayer, 7
applies for, and receives pre-approval for a tax credit from 8
the Secretary of Education in coordination with the Sec-9
retary of the Treasury. 10
(c) N
ATIONAL ANDSTATECAPS ONCREDITS.— 11
(1) N
ATIONAL CAP.—There is a cap of 12
$10,000,000,000 on the sum of the contributions 13
that qualify for a credit under section 25F and sec-14
tion 45BB of the Internal Revenue Code of 1986 for 15
each calendar year, of which— 16
(A) $5,000,000,000 shall be allotted for 17
qualified contributions to eligible scholarship- 18
granting organizations; and 19
(B) $5,000,000,000 shall be allotted for 20
qualified contributions to eligible workforce 21
training organizations. 22
(2) A
LLOCATION OF CAP.— 23
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(A) INITIAL ALLOCATIONS.—For each cal-1
endar year, the Secretary of Education, in co-2
ordination with the Secretary of Labor, shall— 3
(i) from the amount allotted under 4
paragraph (1)(A)— 5
(I) first reserve, for each State, 6
an amount equal to the sum of the 7
qualifying contributions made in the 8
State in the previous year; and 9
(II) next, allocate the remaining 10
amount among the participating 11
States by allocating to each State the 12
sum of— 13
(aa) an amount that bears 14
the same relationship to 20 per-15
cent of such remaining amount 16
as the number of individuals 17
aged 5 through 17 in the State, 18
as determined by the Secretary of 19
Education on the basis of the 20
most recent satisfactory data, 21
bears to the number of those in-22
dividuals in all such States, as so 23
determined; and 24
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(bb) an amount that bears 1
the same relationship to 80 per-2
cent of such remaining amount 3
as the number of individuals 4
aged 5 through 17 from families 5
with incomes below the poverty 6
line in the State, as determined 7
by the Secretary of Education, on 8
the basis of the most recent sat-9
isfactory data, bears to the num-10
ber of those individuals in all 11
such States, as so determined; 12
and 13
(ii) from the amount allotted under 14
paragraph (1)(B)— 15
(I) first reserve, for each State, 16
an amount equal to the sum of the 17
qualifying contributions made in the 18
State in the previous year attributable 19
to eligible workforce training organi-20
zations; and 21
(II) next, allocate the remaining 22
amount among the participating 23
States by allocating to each State an 24
amount determined through a system, 25
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as established and maintained by the 1
Secretary of Labor, that accurately 2
reflects demand and potential quali-3
fied participants for apprenticeships 4
and workforce training within that 5
State. 6
(B) M
INIMUM ALLOCATION .—Notwith-7
standing subparagraph (A), no State receiving 8
an allotment under this section may receive less 9
than one-half of one percent of the amount al-10
lotted for a fiscal year. 11
(C) A
LTERNATIVE ALLOCATION FOR 12
QUALIFIED CONTRIBUTIONS TO ELIGIBLE 13
SCHOLARSHIP-GRANTING ORGANIZATIONS .— 14
(i) I
N GENERAL.—Not later than the 15
end of the fifth year of the program or one 16
year after the end of the first fiscal year 17
for which the total amount of credits 18
claimed under section 25F and section 19
45BB of the Internal Revenue Code of 20
1986 for qualified contributions to eligible 21
scholarship-granting organizations is 22
$2,500,000,000 or more, whichever comes 23
first, the Secretary of Education shall, by 24
regulation, provide for an alternative allo-25
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cation method for the amount described in 1
paragraph (1)(A) that shall take effect be-2
ginning with the first fiscal year after the 3
regulation takes effect. 4
(ii) A
LTERNATIVE ALLOCATION METH -5
OD.—The alternative allocation method de-6
scribed in clause (i) shall be expressed as 7
a formula based on a combination of the 8
following data for each State, as reported 9
by the State to the Secretary of Education: 10
(I) The relative percentage of 11
students in the State who receive an 12
elementary or secondary scholarship 13
through a State program that is fi-14
nanced through State tax-credited do-15
nations or appropriations and that 16
permits the elementary or secondary 17
scholarship to be used to attend a pri-18
vate school. 19
(II) The total amount of all ele-20
mentary and secondary scholarships 21
awarded through a State program 22
that is financed through State tax- 23
credited donations or appropriations 24
compared to the total amount of cur-25
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rent State and local expenditures for 1
free public education in the State. 2
(iii) A
LLOCATION FORMULA .—For any 3
fiscal year to which clause (i) applies, the 4
Secretary of Education shall— 5
(I) first reserve, for each State, 6
an amount equal to the sum of the 7
qualifying contributions made in the 8
State in the previous year; 9
(II) next, allocate two-thirds of 10
the remaining amount of the national 11
cap for that year using the alternative 12
allocation method in clause (ii); and 13
(III) then, allocate one-third of 14
the remaining amount in accordance 15
with subparagraph (A)(ii). 16
(iv) I
NELIGIBILITY.—For any fiscal 17
year to which clause (i) applies, a State 18
that does not provide the Secretary of 19
Education with information described in 20
clause (ii) is not eligible to receive an allo-21
cation through the alternative allocation 22
method under clause (ii). 23
(3) A
LLOWABLE PARTNERSHIPS .—A State may 24
choose to administer the allocation it receives under 25
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paragraph (2) in partnership with one or more 1
States, provided that the eligible scholarship-grant-2
ing organizations or eligible workforce training orga-3
nizations in each partner State serve students who 4
reside in all States in the partnership. 5
(4) T
OTAL ALLOCATION.—A State’s allocation, 6
for any fiscal year, is the sum of the amount deter-7
mined for it under subparagraphs (A) and (B) of 8
paragraph (2), except as provided in paragraph 9
(2)(C). 10
(5) A
LLOCATION AND ADJUSTMENTS .— 11
(A) I
NITIAL ALLOCATION TO STATES .—No 12
later than November 1 of the year preceding a 13
year for which there is a national cap on credits 14
under paragraph (1) (hereafter in this section, 15
the ‘‘applicable year’’), or as early as prac-16
ticable with respect to the first year, the Sec-17
retary of Education shall announce the State 18
allocations under paragraph (2) for the applica-19
ble year. 20
(B) L
IST OF ELIGIBLE SCHOLARSHIP - 21
GRANTING ORGANIZATIONS AND ELIGIBLE 22
WORKFORCE TRAINING ORGANIZATIONS .—No 23
later than January 1 of each applicable year, or 24
as early as practicable with respect to the first 25
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•S 370 IS
year, each State shall provide the Secretary of 1
Education a list of eligible scholarship-granting 2
organizations and eligible workforce training or-3
ganizations described in paragraphs (3)(A) and 4
(4) of section 25F(c) of the Internal Revenue 5
Code of 1986, including a certification that the 6
entity submitting the list on behalf of the State 7
has the authority to perform this function. Nei-8
ther this Act nor any other Federal law shall be 9
construed as limiting the entities that may sub-10
mit the list on behalf of a State. 11
(C) R
EALLOCATION.— 12
(i) I
N GENERAL.—The Secretary of 13
Education shall, in accordance with para-14
graph (2), reallocate to any other States 15
the allocation of a State which, for any ap-16
plicable year— 17
(I) fails to provide the Secretary 18
of Education a list of eligible scholar-19
ship-granting organizations and eligi-20
ble workforce training organizations 21
pursuant to subparagraph (B); and 22
(II) does not have an eligible 23
scholarship-granting organization (as 24
described in section 25F(c)(3)(B) of 25
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•S 370 IS
the Internal Revenue Code of 1986) 1
located in such State. 2
(ii) U
NCLAIMED CREDITS .—On or 3
after April 1 of any applicable year, the 4
Secretary of Education may reallocate, to 5
one or more other States that have eligible 6
scholarship-granting organizations and eli-7
gible workforce training organizations in 8
the States, without regard to paragraph 9
(2), the allocation of a State for which the 10
State’s allocation has not been claimed. 11
(d) D
EFINITIONS.—The definitions of terms in sec-12
tion 25F(c) of the Internal Revenue Code of 1986 apply 13
to those terms as used in this title. 14
(e) A
UTHORIZATION OF APPROPRIATIONS.—For the 15
purpose of administering this section and sections 25F 16
and 45BB of the Internal Revenue Code of 1986, there 17
are authorized to be appropriated, and there are appro-18
priated, such sums as may be necessary for fiscal year 19
2025 and each succeeding fiscal year. 20
Æ
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