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Courts gain power to override tax claims in receivership cases

H.R. 5146 — Federal Receivership Fairness Act · Filed by Darin LaHood (R-IL) · 2 cosponsors · Introduced Sep 4, 2025 · Referred to committee

72%
Transparency
Typical bill: 85%
25/100
Hidden-provision risk
Typical bill: 15/100
Receivership Tax Procedure Reform

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What it does

This bill creates a new federal rule allowing courts overseeing receivership cases (when a business or entity is placed under court-appointed management) to determine what taxes the receivership estate owes to federal, state, or local governments. It sets a 60-day window for tax authorities to audit the receiver's tax return, and a 180-day window to complete the audit and notify the receiver of any tax due; if those deadlines pass, the estate is discharged from that tax liability upon payment of what the receiver reported. The bill also strips sovereign immunity from government tax agencies in receivership disputes, allowing courts to order them to pay money judgments and offset their claims against the estate's claims against them.

Why we flagged it

The bill's core function is procedural: it establishes a new mechanism for resolving tax disputes in receivership cases by giving courts authority and imposing time limits on tax authorities. It is not a tax cut or subsidy, but a reallocation of dispute-resolution power from tax agencies to courts.

What the text implies

  • The 60/180-day deadline may force tax authorities to rush audits or lose claims entirely, potentially allowing underpayment of legitimate taxes owed by insolvent estates.
  • Abrogation of sovereign immunity exposes state and local tax agencies to federal court jurisdiction and money judgments, which may strain budgets of smaller municipalities already managing tax collection.
  • The offset provision (subsection g) allows receivership estates to reduce tax claims by asserting counterclaims against the government, creating leverage that may incentivize settlement over collection.
  • Courts may lack tax expertise to determine complex tax liabilities, potentially creating inconsistent outcomes across jurisdictions and inviting litigation over tax determinations that would normally be resolved administratively.

Section numbers refer to the bill text the analysis read — linked under Primary records below.

Who it affects

The bill protects receivership estates and their creditors from indefinite tax claims by imposing strict deadlines on tax authorities, which benefits businesses in financial distress and their stakeholders. However, it also allows courts to override tax determinations made by elected tax authorities and strips those authorities of sovereign immunity, potentially reducing tax collection and shifting costs to taxpayers who fund those governments.

Who stands to gain

  • businesses and entities in receivership
  • creditors of receivership estates
  • receivers and court-appointed administrators

Named in the bill

Internal Revenue Service (IRS), Federal courts, State and local tax authorities, Receivership estates, Receivers (court-appointed), United States District Courts

Where it stands

2 cosponsors: 2 Democrats.

  • Sep 4, 2025 — Introduced · Congress.gov: “Introduced in House”
  • Sep 4, 2025 — Referred to House Committee on the Judiciary and House Committee on Ways and Means · Congress.gov: “Referred to the Committee on Ways and Means, and in addition to the Committee on the Judiciary, for a period…”

Dates and quoted wording are Congress.gov's action record; the timeline shows status changes, not every procedural step.

Money around this bill

1 lobbying clients named this bill on 1 disclosure filings across 1 quarter, Jun 2026 to Jun 2026. Those filings disclosed $20,000 in lobbying spend. A filing names 1 bills on average, so that figure is what each filing reported, not a share belonging to this bill.

More lobbying clients named this bill than 0% of bills with at least one filing.

Darin LaHood, the sponsor, reported $1,817,841 in PAC receipts in the 2026 cycle.

  • National Association of Federal Equity Receivers (nafer) — $20,000 on 1 filing

Lobbying Disclosure Act filings through Jul 19, 2026. A filing shows who paid to lobby on a bill it names, not what changed.

How this was measured

Analysis — Quorum's AI read the bill text published by Congress.gov (8,583 characters) on Sep 26, 2026. Section numbers in the findings refer to that text, linked below; transparency and hidden-provision scores are compared against the median of 15,166 analysed bills.

Status and sponsors — Congress.gov's bill record — actions, committee referrals and cosponsors — loaded nightly. The timeline shows status changes, not every procedural action.

Money — Senate Lobbying Disclosure Act filings whose specific-issue field names this bill for quarters ending Jun 2026 to Jun 2026. A filing's amount is reported whole beside the median number of bills a filing names; it is never divided across them. PAC receipts are FEC-reported contributions to the sponsor's candidate committee in the 2026 cycle.

As of — lobbying records through Jul 19, 2026 · page rendered 2026-09-26.

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Correlative observation from public records — not evidence of coordination or wrongdoing, and not financial advice.
This page is the record as of today. The app tells you when it changes.
Quorum analysis of the full bill text · 119th Congress · public record