Taxpayers' Procedural Safeguard Act

Taxpayers' Procedural Safeguard Act - Amends the Internal Revenue Code to increase from ten days to 30 days the time period during which a taxpayer must pay a tax deficiency after notice and demand for payment. Sets forth requirements for information which must be included with such notice to a taxpayer.

Allows the release of a levy upon the wages or salary of a taxpayer if: (1) the taxpayer has entered into an agreement for the payment of tax liability; or (2) the Secretary of the Treasury determines that such liability is unenforceable due to the financial condition of the taxpayer. (Present law allows the release of a levy only when the liability is satisfied or becomes unenforceable due to lapse of time.) Increases by specified amounts the aggregate sum of a taxpayer's personal effects and trade or business property which is exempt from levy. Increases by specified amounts the wages, salary, and other income of a taxpayer which are exempt from levy.

Exempts from levy: (1) the principal residence of the taxpayer; (2) any motor vehicle used for transportation to the place of business of the taxpayer; and (3) any tangible personal property used in carrying on the trade or business of the taxpayer if such levy would prevent the taxpayer from carrying on such trade or business. Allows levy on such property if: (1) a district director or assistant district director of the Internal Revenue Service personally approves (in writing) the levy of such property; or (2) the collection of tax would be in jeopardy.

Prohibits the levy on any property if the amount of the estimated expenses which would be incurred with respect to the levy and sale of such property exceeds: (1) the fair market value of such property at the time of levy; or (2) the liability for which such levy is made.

Revises requirements for the administrative review of jeopardy levy and assessment. Requires the award of court costs and certain fees in civil suits brought against the United States if the position of the United States in such a proceeding was not substantially justified.

Authorizes the Secretary to enter into written agreements with a taxpayer providing for installment payments of tax liability if the Secretary determines that such an agreement will facilitate the collection of the tax liability. Requires the Secretary to make a written offer to enter into such an agreement if: (1) the taxpayer's liability does not exceed $20,000; and (2) the taxpayer has not been delinquent in payments under any other such agreement during the previous three years. Provides that such an agreement shall be binding upon the Secretary unless: (1) information provided by the taxpayer was inaccurate or incomplete; or (2) the Secretary determines that the financial condition of the taxpayer has significantly changed.

Requires the abatement of deficiency and any penalty or interest attributable to written advice by the Internal Revenue Service.

Sets forth procedures for taxpayer interviews. Requires the Internal Revenue Service, upon a taxpayer's request, to: (1) conduct such an interview at a reasonable time and place convenient to the taxpayer; and (2) allow the taxpayer to make a recording of such interview. Requires the officer or employee conducting such interview to warn the taxpayer that: (1) he has the right to remain silent; (2) any statement he makes may be used against him; and (3) he has the right to the presence of an attorney, accountant, or return preparer.

Establishes within the Internal Revenue Service an Office of Ombudsman. Sets forth the duties and responsibilities of the Ombudsman. Requires the Ombudsman to submit annual reports to specified congressional committees.

Authorizes the Ombudsman, upon application filed by a taxpayer, to issue a Taxpayer Assistance Order if, in the determination of the Ombudsman: (1) the taxpayer is suffering or about to suffer from an unusual or irreparable loss as a result of the manner in which the internal revenue laws are being administered by the Secretary; and (2) the Secretary has failed to carry out any of his duties or has violated any provision of law. Allows the terms of a taxpayer assistance order to require the Secretary to: (1) release property of the taxpayer levied upon; or (2) cease or refrain from certain actions. Requires the Secretary to obey any Taxpayer Assistance Order issued by the Ombudsman.

Allows an administrative appeal of tax liens.

Provides for a civil cause of action by a taxpayer for a wrongful lien or levy upon property.