To amend the Internal Revenue Code of 1986 to place the burden of proof on the Secretary of the Treasury in civil cases and on the taxpayer in administrative proceedings, to require 15 days notice and judicial consent before seizure, to exclude civil damages for unauthorized collection actions from income, and for other purposes.

Amends the Internal Revenue Code to place the burden of proof on the taxpayer in the case of any administrative proceeding and on the Secretary of the Treasury in the case of any court proceeding. Requires a 30-day notice before seizure. Prohibits the Secretary from collecting any tax (or other sum) by levy without judicial consent. Excludes from gross income damages awarded for unauthorized IRS collection activities. Requires a study of the revenue losses (if any) resulting from this Act.