II
119THCONGRESS
1
STSESSION S. 588
To amend the Internal Revenue Code of 1986 to provide for examination
and disclosure with respect to Presidential income tax returns, to amend
chapter 131 of title 5, United States Code, to require the disclosure
of certain tax returns by Presidents and certain candidates for the
office of the President, and for other purposes.
IN THE SENATE OF THE UNITED STATES
FEBRUARY13, 2025
Mr. W
YDEN(for himself, Ms. KLOBUCHAR, Mr. KAINE, Ms. WARREN, Mr.
M
ERKLEY, Mr. WHITEHOUSE, Mr. SANDERS, Ms. CANTWELL, and Mr.
V
ANHOLLEN) introduced the following bill; which was read twice and re-
ferred to the Committee on Finance
A BILL
To amend the Internal Revenue Code of 1986 to provide
for examination and disclosure with respect to Presi-
dential income tax returns, to amend chapter 131 of
title 5, United States Code, to require the disclosure
of certain tax returns by Presidents and certain can-
didates for the office of the President, 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
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SECTION 1. SHORT TITLE. 1
This Act may be cited as the ‘‘Presidential Audit and 2
Tax Transparency Act’’. 3
SEC. 2. EXAMINATION AND DISCLOSURE WITH RESPECT TO 4
PRESIDENTIAL INCOME TAX RETURNS. 5
(a) A
UDIT.—Subchapter A of chapter 78 of the Inter-6
nal Revenue Code of 1986 is amended by redesignating 7
section 7613 as section 7614 and by inserting after section 8
7612 the following new section: 9
‘‘SEC. 7613. EXAMINATION WITH RESPECT TO PRESI-10
DENTIAL INCOME TAX RETURNS. 11
‘‘(a) I
NGENERAL.—As rapidly as practicable after 12
the filing of any Presidential income tax return, the Sec-13
retary shall conduct an examination to ascertain the cor-14
rectness of such return and enforce the requirements of 15
this title with respect to the taxable year covered by such 16
return. 17
‘‘(b) R
EPORTS.— 18
‘‘(1) I
NITIAL REPORT.—Not later than 90 days 19
after the filing of a Presidential income tax return, 20
the Secretary shall disclose and make publicly avail-21
able an initial report regarding the examination with 22
respect to such return. Such report shall include— 23
‘‘(A) the name of the taxpayer, 24
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‘‘(B) an identification of the subparagraph 1
of subsection (c)(1) which describes such re-2
turn, 3
‘‘(C) the date that such return was filed, 4
and 5
‘‘(D) the date on which the examination 6
with respect to such return commenced (or, if 7
such examination has not commenced as of the 8
date of such report, a detailed description of the 9
reasons that such examination has not com-10
menced). 11
‘‘(2) P
ERIODIC REPORTS.—Not later than 180 12
days after the disclosure of the report described in 13
paragraph (1) with respect to any Presidential in-14
come tax return and not later than 180 days after 15
the most recent disclosure of a report described in 16
this paragraph with respect to such return, the Sec-17
retary shall disclose and make publicly available a 18
periodic report regarding the examination with re-19
spect to such return. Such report shall include— 20
‘‘(A) the information described in subpara-21
graphs (A) through (D) of paragraph (1), 22
‘‘(B) a description of the status of the ex-23
amination, including a description of the por-24
tions of the examination which have been com-25
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pleted, which are in process, and which are an-1
ticipated to take place, and 2
‘‘(C) an estimate of the time frame for the 3
completion of the examination, including an 4
identification of factors which could alter such 5
time frame, reasonable estimates of the likeli-6
hood of such factors (taking into account the 7
specific facts and circumstances of the examina-8
tion), and the likely specific effects of such fac-9
tors on such time frame. 10
Notwithstanding the preceding sentence, a periodic 11
report shall not be required under this paragraph 12
with respect to any return after the date on which 13
a final report is disclosed under paragraph (3) with 14
respect to such return. 15
‘‘(3) F
INAL REPORT.—Not later than 90 days 16
after the completion of the examination described in 17
subsection (a) with respect to any Presidential in-18
come tax return, the Secretary shall disclose and 19
make publicly available a final report regarding such 20
examination. Such report shall include— 21
‘‘(A) the information described in subpara-22
graphs (A) through (C) of paragraph (1), 23
‘‘(B) the date on which the examination 24
with respect to such return was completed, 25
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‘‘(C) a list of the audit materials (as de-1
fined in section 6103(q)(2)) with respect to 2
such examination, and 3
‘‘(D) a description (including the amount) 4
of each proposed adjustment, adjustment, and 5
controversy with respect to such examination 6
together with a description of how such pro-7
posed adjustment or controversy was resolved 8
(or a statement that such proposed adjustment 9
or controversy was not resolved, as the case 10
may be). 11
For purposes of this paragraph, an examination 12
shall be treated as complete on the date that the 13
Secretary provides the taxpayer with a notice of defi-14
ciency, or any closing document referred to in sec-15
tion 6103(q)(2)(A)(v), with respect to such examina-16
tion. 17
‘‘(4) E
XTENSION OF DUE DATE REPORT .—If a 18
request is made for an extension of the due date for 19
filing any Presidential income tax return, the Sec-20
retary shall, not later than 90 days after such re-21
quest is granted or denied, disclose and make pub-22
licly available an extension of due date report with 23
respect to return. Such report shall include— 24
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‘‘(A) the information described in subpara-1
graphs (A) and (B) of paragraph (1), 2
‘‘(B) a statement that an extension of the 3
due date for the filing of such return has been 4
requested, 5
‘‘(C) the date that such request was re-6
ceived, 7
‘‘(D) a statement of whether such request 8
has been granted or denied, and 9
‘‘(E) the due date of such return (includ-10
ing any extensions). 11
‘‘(5) T
REATMENT OF FAILURE TO FILE .—In 12
the case of a failure to file a Presidential income tax 13
return before the close of the 60-day period begin-14
ning with the date prescribed for filing of such re-15
turn— 16
‘‘(A) the Secretary shall conduct the exam-17
ination described in subsection (a) with respect 18
to the taxable year covered by the return to 19
which such failure relates, 20
‘‘(B) reports made pursuant to this para-21
graph shall include a statement that such re-22
port is with respect to a return which the tax-23
payer failed to file, and 24
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‘‘(C) this section and section 6103(q) shall 1
otherwise apply to such failure in the same 2
manner as if a return were filed at the close of 3
such period. 4
The application of this paragraph with respect to 5
any failure to file a Presidential income tax return 6
shall not prevent the application of this section with 7
respect to such return at such time as such return 8
may be filed. 9
‘‘(6) P
UBLIC AVAILABILITY.—For purposes of 10
this subsection, a document shall not be treated as 11
having been made publicly available unless made 12
available on the Internet. 13
‘‘(c) P
RESIDENTIALINCOMETAXRETURN.—For 14
purposes of this section— 15
‘‘(1) I
N GENERAL.—The term ‘Presidential in-16
come tax return’ means any relevant income tax re-17
turn of— 18
‘‘(A) a President, 19
‘‘(B) an individual who is married (within 20
the meaning of section 7703(a)) to a President 21
for the taxable year to which such return re-22
lates, 23
‘‘(C) any corporation or partnership which 24
is controlled by any individual described in sub-25
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paragraph (A) or (B) at any time during the 1
taxable year to which such return relates, 2
‘‘(D) the estate of any person described in 3
(A) or (B) or any estate with respect to which 4
any person described in subparagraph (A), (B), 5
or (C) is an executor or beneficiary at any time 6
during the taxable year to which such return 7
relates, and 8
‘‘(E) any trust with respect to which any 9
person described in subparagraph (A), (B), (C), 10
or (D) is a grantor, fiduciary, or beneficiary, or 11
for which another trust described in this sub-12
paragraph is a grantor or beneficiary, at any 13
time during the taxable year to which such re-14
turn relates. 15
Such term shall include any schedule, attachment, or 16
other document filed with such return. 17
‘‘(2) R
ELEVANT INCOME TAX RETURN .—The 18
term ‘relevant income tax return’ means, with re-19
spect to a President, any income tax return if— 20
‘‘(A) any portion of the taxable year to 21
which such return relates is during the period 22
that such President is the President, 23
‘‘(B) the due date for such return (includ-24
ing any extensions) is during such period, or 25
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‘‘(C) such return is filed during such pe-1
riod. 2
‘‘(3) C
ONTROL.—For purposes of paragraph 3
(1)(C)— 4
‘‘(A) I
N GENERAL.—Except as otherwise 5
provided in this paragraph, control shall be de-6
termined under the rules of paragraphs (2) and 7
(3) of section 6038(e) (determined without re-8
gard to subparagraphs (A) and (B) of such 9
paragraph (2) and without regard to subpara-10
graph (C) of paragraph (3) thereof). 11
‘‘(B) R
ESTRICTION ON FAMILY ATTRIBU -12
TION.— 13
‘‘(i) I
N GENERAL.—Except as pro-14
vided in clause (ii), for purposes of apply-15
ing subparagraph (A)— 16
‘‘(I) section 318 shall be applied 17
without regard to subsection 18
(a)(1)(A)(ii) thereof, and 19
‘‘(II) section 267(c) shall be ap-20
plied by treating the family of an indi-21
vidual as including only such individ-22
ual’s spouse (in lieu of the application 23
of paragraph (4) thereof). 24
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‘‘(ii) EXCEPTION FOR RECENT TRANS -1
FER TO FAMILY MEMBERS .—For purposes 2
of determining whether any corporation or 3
partnership is controlled by a President 4
under paragraph (1)(C) for any taxable 5
year, clause (i) shall not apply if such cor-6
poration or partnership was controlled by 7
such President (after application of clause 8
(i)) at any time during the 4 immediately 9
preceding taxable years. 10
‘‘(d) A
PPLICATION TO AMENDEDRETURNS.—For 11
purposes of this section and section 6103(q), any amend-12
ment or supplement to a return of tax shall be treated 13
as a separate return of tax and the determination of when 14
such amendment or supplement is filed, and whether such 15
amendment or supplement is a relevant income tax return, 16
shall be made without regard to the underlying return.’’. 17
(b) D
ISCLOSURE.—Section 6103 of such Code is 18
amended by redesignating subsection (q) as subsection (r) 19
and by inserting after subsection (p) the following new 20
subsection: 21
‘‘(q) D
ISCLOSUREWITHRESPECT TOPRESIDENTIAL 22
I
NCOMETAXRETURNS.— 23
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‘‘(1) IN GENERAL.—The Secretary shall dis-1
close and make publicly available (within the mean-2
ing of section 7613(b))— 3
‘‘(A) each Presidential income tax return 4
(as defined in section 7613(c)), 5
‘‘(B) each report described in section 6
7613(b), and 7
‘‘(C) any audit materials with respect a re-8
turn described in subparagraph (A). 9
‘‘(2) A
UDIT MATERIALS.—The term ‘audit ma-10
terials’ means, with respect to any return: 11
‘‘(A) Any of the following which are pro-12
vided by the Secretary to the taxpayer (or any 13
designee of the taxpayer): 14
‘‘(i) Any written communication which 15
identifies such return as being subject to 16
examination. 17
‘‘(ii) Any written communication 18
which proposes the adjustment of any item 19
on such return, any report by an examiner 20
related to such proposed adjustment, and 21
any supervisory approval of any penalty 22
proposed as part of such adjustment. 23
‘‘(iii) Any memorandum or report of 24
the Internal Revenue Service Independent 25
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Office of Appeals with respect to such re-1
turn, and any denial of any request de-2
scribed in subparagraph (B). 3
‘‘(iv) Any notice of deficiency with re-4
spect to such return. 5
‘‘(v) Any closing documents with re-6
spect to the examination of such return, 7
including any closing agreement or no 8
change letter. 9
‘‘(B) Any request for referral to the Inter-10
nal Revenue Service Independent Office of Ap-11
peals of any controversy with respect to such 12
return. 13
‘‘(C) Any petition filed with the Tax Court 14
for a redetermination of any deficiency referred 15
to in subparagraph (A)(iv). 16
‘‘(3) E
XCEPTION FOR CERTAIN IDENTITY IN -17
FORMATION.—The information disclosed and made 18
publicly available under paragraph (1) shall not in-19
clude any identification number of any person (in-20
cluding any social security number), any financial 21
account number, the name of any individual who has 22
not attained age 18 (as of the close of the taxable 23
year to which the return relates), the name of any 24
employee of the Department of the Treasury, or any 25
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address (other than the city and State in which such 1
address is located). 2
‘‘(4) T
IMING OF DISCLOSURES .—Any informa-3
tion required to be disclosed under paragraph (1) 4
shall be disclosed and made publicly available not 5
later than— 6
‘‘(A) in the case of any income tax return 7
referred to in paragraph (1)(A), 90 days after 8
the date that such return is filed, 9
‘‘(B) in the case of any report referred to 10
in paragraph (1)(B), the deadline specified in 11
section 7613(b) for disclosing such report, and 12
‘‘(C) in the case of the audit materials re-13
ferred to in paragraph (1)(C), 90 days after the 14
completion of the examination (within the 15
meaning of section 7613(b)(3)) with respect to 16
the return to which such audit materials re-17
late.’’. 18
(c) C
LERICALAMENDMENT.—Subchapter A of chap-19
ter 78 of such Code is amended by redesignating the item 20
relating to section 7613 as an item relating to section 21
7614 and by inserting after the item relating to section 22
7612 the following new item: 23
‘‘Sec. 7613. Examination with respect to Presidential income tax returns.’’.
(d) EFFECTIVEDATE.—The amendments made by 24
this subsection shall apply to returns, amendments, and 25
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supplements filed (and failures to file returns which occur) 1
after the date of the enactment of this Act (and to reports 2
and audit materials with respect to such returns, amend-3
ments, supplements, and failures). 4
SEC. 3. ADDITIONAL DISCLOSURE OF TAX RETURNS BY 5
PRESIDENTS AND CERTAIN PRESIDENTIAL 6
CANDIDATES. 7
(a) I
NGENERAL.— 8
(1) D
ISCLOSURE REQUIREMENT .—Chapter 131 9
of title 5, United States Code, is amended— 10
(A) by inserting after section 13104 the 11
following: 12
‘‘SEC. 13104A. DISCLOSURE OF TAX RETURNS. 13
‘‘(a) D
EFINITIONS.—In this section: 14
‘‘(1) A
PPLICABLE INCOME TAX RETURN .— 15
‘‘(A) I
N GENERAL.—The term ‘applicable 16
income tax return’ means, with respect to any 17
taxable year, any return (within the meaning of 18
section 6103(b) of the Internal Revenue Code 19
of 1986) relating to Federal income taxes of— 20
‘‘(i) a covered candidate or covered in-21
dividual; 22
‘‘(ii) an individual who is married 23
(within the meaning of section 7703(a) of 24
the Internal Revenue Code of 1986) to a 25
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covered candidate or covered individual for 1
the taxable year; 2
‘‘(iii) any corporation or partnership 3
that was controlled (as determined under 4
section 7613(c)(3) of the Internal Revenue 5
Code of 1986) by an individual described 6
in clause (i) or (ii) at any time during the 7
taxable year; 8
‘‘(iv) the estate of any person de-9
scribed in clause (i) or (ii) or any estate 10
with respect to which any person described 11
in clause (i), (ii), or (iii) is an executor or 12
beneficiary at any time during the taxable 13
year; and 14
‘‘(v) any trust with respect to which 15
any person described in clause (i), (ii), 16
(iii), or (iv) is a grantor, fiduciary, or ben-17
eficiary, or for which another trust de-18
scribed in this clause is a grantor or bene-19
ficiary, at any time during the taxable 20
year. 21
‘‘(B) I
NCLUSION OF CERTAIN DOCU -22
MENTS.—Such term shall include any schedule, 23
attachment, or other document filed with such 24
return. 25
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‘‘(2) COVERED CANDIDATE .—The term ‘covered 1
candidate’ means an individual— 2
‘‘(A) required to file a report under section 3
13103(c); and 4
‘‘(B) who is nominated by a major party 5
as a candidate for the office of President, re-6
gardless of whether the individual is nominated 7
after May 15 of an applicable year. 8
‘‘(3) C
OVERED INDIVIDUAL .—The term ‘cov-9
ered individual’ means— 10
‘‘(A) a President required to file a report 11
under subsection (a) or (d) of section 13103; 12
and 13
‘‘(B) an individual who occupies the office 14
of the President required to file a report under 15
section 13103(e). 16
‘‘(4) M
AJOR PARTY.—The term ‘major party’ 17
has the meaning given the term in section 9002 of 18
the Internal Revenue Code of 1986. 19
‘‘(b) D
ISCLOSURE.— 20
‘‘(1) C
OVERED INDIVIDUALS.— 21
‘‘(A) I
N GENERAL.—In addition to the in-22
formation described in subsections (a) and (b) 23
of section 13104, a covered individual shall in-24
clude in each report required to be filed under 25
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this title a copy of all applicable income tax re-1
turns for the 3 most recent taxable years for 2
which a return has been filed with the Internal 3
Revenue Service as of the date on which the re-4
port is filed. 5
‘‘(B) F
AILURE TO DISCLOSE .—If an in-6
come tax return is not disclosed under subpara-7
graph (A), the Director of the Office of Govern-8
ment Ethics shall submit to the Secretary of 9
the Treasury a request that the Secretary of 10
the Treasury provide the Director of the Office 11
of Government Ethics with a copy of the in-12
come tax return. 13
‘‘(C) P
UBLICLY AVAILABLE.—Each income 14
tax return submitted or provided under this 15
paragraph shall be filed with the Director of the 16
Office of Government Ethics and made publicly 17
available in the same manner as the informa-18
tion described in subsections (a) and (b) of sec-19
tion 13104. 20
‘‘(D) R
EDACTION OF CERTAIN INFORMA -21
TION.—Before making any income tax return 22
submitted under this paragraph available to the 23
public, the Director of the Office of Government 24
Ethics shall redact such information as the Di-25
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rector of the Office of Government Ethics, in 1
consultation with the Secretary of the Treasury 2
(or a delegate of the Secretary), determines ap-3
propriate. 4
‘‘(2) C
OVERED CANDIDATES .— 5
‘‘(A) I
N GENERAL.—Not later than 15 6
days after the date on which a covered can-7
didate is nominated, the covered candidate shall 8
amend the report filed by the covered candidate 9
under section 13103(c) with the Federal Elec-10
tion Commission to include a copy of the appli-11
cable income tax returns for the 3 most recent 12
taxable years for which a return has been filed 13
with the Internal Revenue Service. 14
‘‘(B) F
AILURE TO DISCLOSE.—If an appli-15
cable income tax return is not disclosed under 16
subparagraph (A), the Federal Election Com-17
mission shall submit to the Secretary of the 18
Treasury a request that the Secretary of the 19
Treasury provide the Federal Election Commis-20
sion with the applicable income tax return. 21
‘‘(C) P
UBLICLY AVAILABLE.—Each appli-22
cable income tax return submitted or provided 23
under this paragraph shall be filed with the 24
Federal Election Commission and made publicly 25
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available in the same manner as the informa-1
tion described in section 13104(b). 2
‘‘(D) R
EDACTION OF CERTAIN INFORMA -3
TION.—Before making any applicable income 4
tax return submitted under this paragraph 5
available to the public, the Federal Election 6
Commission shall redact such information as 7
the Federal Election Commission, in consulta-8
tion with the Secretary of the Treasury (or a 9
delegate of the Secretary) and the Director of 10
the Office of Government Ethics, determines 11
appropriate. 12
‘‘(3) S
PECIAL RULE WITH RESPECT TO RE -13
TURNS DISCLOSED UNDER OTHER AUTHORITY .—For 14
purposes of this subsection, in the case of any appli-15
cable income tax return that has been made publicly 16
available pursuant to section 6103(q) of the Internal 17
Revenue Code of 1986, the requirements of para-18
graphs (1)(A) and (2)(A) shall be satisfied with re-19
spect to such return if the covered individual or cov-20
ered candidate (as the case may be) provides the lo-21
cation on the Internet where such disclosure has 22
been made publicly available.’’; and 23
(B) in section 13106— 24
(i) in subsection (a)— 25
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(I) in paragraph (1), in the first 1
sentence, by inserting ‘‘or any indi-2
vidual who knowingly and willfully fal-3
sifies or who knowingly and willfully 4
fails to file an applicable income tax 5
return that such individual is required 6
to disclose pursuant to section 7
13104A of this title’’ before the pe-8
riod; and 9
(II) in paragraph (2)(A)— 10
(aa) in clause (i), by insert-11
ing ‘‘or falsify any applicable in-12
come tax return that such person 13
is required to disclose under sec-14
tion 13104A of this title’’ before 15
the semicolon; and 16
(bb) in clause (ii), by insert-17
ing ‘‘or fail to file any applicable 18
income tax return that such per-19
son is required to disclose under 20
section 13104A of this title’’ be-21
fore the period; 22
(ii) in subsection (b), in the first sen-23
tence, by inserting ‘‘or willfully failed to 24
file or has willfully falsified an applicable 25
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income tax return required to be disclosed 1
under section 13104A’’ before the period; 2
(iii) in subsection (c), by inserting ‘‘or 3
failing to file or falsifying an applicable in-4
come tax return required to be disclosed 5
under section 13104A’’ before the period; 6
and 7
(iv) in subsection (d)(1)— 8
(I) in the matter preceding sub-9
paragraph (A), by inserting ‘‘or files 10
an applicable income tax return re-11
quired to be disclosed under section 12
13104A’’ after ‘‘subchapter’’; and 13
(II) in subparagraph (A), by in-14
serting ‘‘or such applicable income tax 15
return, as applicable,’’ after ‘‘report’’. 16
(2) S
PECIAL RULE FOR INDIVIDUALS WHO ARE 17
COVERED CANDIDATES ON DATE OF ENACTMENT .— 18
In the case of any individual who is a covered can-19
didate (as defined in section 13104A of title 5, 20
United States Code, as added by paragraph (1)) on 21
the date of the enactment of this Act, section 22
13104A(b)(2)(A) shall be applied by substituting 23
‘‘30 days after the date of the enactment of the 24
Presidential Audit and Tax Transparency Act’’ for 25
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‘‘15 days after the date on which a covered can-1
didate is nominated’’. 2
(3) C
LERICAL AMENDMENT .—The table of sec-3
tions for chapter 131 of title 5, United States Code, 4
is amended by adding at the end the following: 5
‘‘13104A. Disclosure of tax returns.’’.
(b) AUTHORITYTODISCLOSEINFORMATION.— 6
(1) I
N GENERAL.—Section 6103(l) of the Inter-7
nal Revenue Code of 1986 is amended by adding at 8
the end the following: 9
‘‘(23) D
ISCLOSURE OF RETURN INFORMATION 10
OF PRESIDENTS AND CERTAIN PRESIDENTIAL CAN -11
DIDATES UNDER CHAPTER 131 OF TITLE 5 , UNITED 12
STATES CODE.— 13
‘‘(A) D
ISCLOSURE OF RETURNS OF PRESI -14
DENTS.— 15
‘‘(i) I
N GENERAL.—The Secretary 16
shall, upon written request from the Direc-17
tor of the Office of Government Ethics 18
pursuant to section 13104A(b)(1)(B) of 19
title 5, United States Code, provide to offi-20
cers and employees of the Office of Gov-21
ernment Ethics a copy of each applicable 22
income tax return with respect to any cov-23
ered individual who has been identified in 24
such request. 25
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‘‘(ii) DISCLOSURE TO PUBLIC .—The 1
Director of the Office of Government Eth-2
ics may disclose to the public any applica-3
ble income tax return required to be sub-4
mitted to the Director pursuant to section 5
13104A(b)(1) of title 5, United States 6
Code. 7
‘‘(B) D
ISCLOSURE OF RETURNS OF CER -8
TAIN CANDIDATES FOR PRESIDENT .— 9
‘‘(i) I
N GENERAL.—The Secretary 10
shall, upon written request from the Chair-11
man of the Federal Election Commission 12
pursuant to section 13104A(b)(2)(B) of 13
title 5, United States Code, provide to offi-14
cers and employees of the Federal Election 15
Commission a copy of each applicable in-16
come tax return with respect to any cov-17
ered candidate who has been identified in 18
such request. 19
‘‘(ii) D
ISCLOSURE TO PUBLIC .—The 20
Federal Election Commission may disclose 21
to the public any applicable income tax re-22
turn required to be filed with the Commis-23
sion pursuant to section 13104A(b)(2) of 24
title 5, United States Code. 25
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‘‘(C) DEFINITIONS.—For purposes of this 1
paragraph, the terms ‘applicable income tax re-2
turn’, ‘covered individual’, and ‘covered can-3
didate’ have the meanings given those terms in 4
section 13104A of title 5, United States Code.’’. 5
(2) C
ONFORMING AMENDMENTS .—Section 6
6103(p)(4) of the Internal Revenue Code of 1986, in 7
the matter preceding subparagraph (A) and in sub-8
paragraph (F)(ii), is amended by striking ‘‘or (22)’’ 9
and inserting ‘‘(22), or (23)’’ each place it appears. 10
Æ
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