S. 4964

S. 4964: A bill to amend the Internal Revenue Code of 1986 to clarify that the exception to the general statute of limitations for fraudulent returns applies only when a taxpayer seeks to evade their tax obligations.

Introduced Roger Marshall (R) SENATE_BILL — 119th Congress
Plain English Summary

S. 4964 is a bill that aims to amend the Internal Revenue Code of 1986. It clarifies that the exception to the general statute of limitations for fraudulent tax returns applies only in cases where a taxpayer has intentionally tried to evade their tax obligations. This means that if a taxpayer is found to have committed fraud, the IRS can pursue legal action beyond the usual time limit only if there is clear evidence of an intent to evade taxes.

Positive Media Summary

Supporters of S. 4964 argue that the bill strengthens the integrity of the tax system by ensuring that only those who intentionally commit fraud can be subject to extended scrutiny. This is seen as a necessary measure to protect honest taxpayers from unjustified audits and to reinforce accountability among those who engage in tax evasion.

Negative Media Summary

Critics of S. 4964 contend that the bill may limit the IRS's ability to effectively address tax fraud by narrowing the circumstances under which the statute of limitations can be extended. Some worry that this could lead to more tax evasion going unpunished, ultimately undermining public trust in the tax system and reducing government revenue.

Conflict of Interest Analysis Deep Analysis
2/10
Risk Level
Low
Total Donations
$0
PAC Percentage
0%
Policy Area
Taxation

The analysis of bill S. 4964, which aims to clarify tax obligations related to fraudulent returns, reveals no direct industry overlaps between the sponsor Roger Marshall's top donor industries and the subject matter of the bill. The top donor industries do not appear to have a vested interest in tax evasion or the specifics of tax code amendments. Additionally, while there is significant lobbying activity in the broader policy area, the amounts from these lobbying entities do not directly correlate to the interests that would be affected by this bill. For instance, the American College of Emergency Physicians contributed $498,299, but their focus is likely on healthcare rather than tax legislation. Therefore, the risk of conflicts of interest is low, as there are no clear financial incentives for the sponsor's donors to influence this legislation.

Lobbying Activity — Who's Pushing?

Organizations that lobbied on issues related to this bill's policy area.

Client Lobbying Firm Amount
AMERICAN COLLEGE OF EMERGENCY PHYSICIANS AMERICAN COLLEGE OF EMERGENCY PHYSICIANS $498,299
TRUST FOR PUBLIC LAND THE TRUST FOR PUBLIC LAND $150,000
COLLIER COLLECTIVE, LLC MCCOLL STRATEGIES LLC $40,000
HART HEALTH STRATEGIES TIM YEHL, LLC $40,000
PANO AI PANO AI $40,000
ALLIANCE FOR AUTOMOTIVE INNOVATION TIM YEHL, LLC $30,000
BSA, THE SOFTWARE ALLIANCE TIM YEHL, LLC $20,000
PSEG SERVICES CORPORATION TIM YEHL, LLC $20,000
COUNTY OF NAPA PARAGON GOVERNMENT RELATIONS $15,000
LAKE COUNTY PARAGON GOVERNMENT RELATIONS $15,000
NEVADA COUNTY PARAGON GOVERNMENT RELATIONS $15,000
HUMBOLDT COUNTY PARAGON GOVERNMENT RELATIONS $15,000
NATIONAL ASSOCIATION OF COUNTY HUMAN SERVICES ADMINISTRATORS PARAGON GOVERNMENT RELATIONS $10,000
NATIONAL CHILD SUPPORT ENFORCEMENT ASSOCIATION PARAGON GOVERNMENT RELATIONS $10,000
CLARK COUNTY PARAGON GOVERNMENT RELATIONS undisclosed

Source: Senate Lobbying Disclosure Act (LDA) filings, 2026

Sponsor's Top Donor Industries

Top industries funding Roger Marshall, ranked by total contributions.

Health Professionals $120,000,000
Individuals: $120,000,000 PACs: $0
Retired $37,500,000
Individuals: $37,500,000 PACs: $0

Source: OpenSecrets.org (Center for Responsive Politics)

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