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 30 days notice and judicial consent before lien or seizure, to increase the limit on recovery of civil damages for unauthorized collection actions and exclude such damages 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 in the case of any court proceeding. Requires a 30-day notice before lien. Prohibits the Secretary from collecting any tax (or other sum) by levy without judicial consent. Requires a 30-day notice before seizure. Increases the limit on the recovery of civil damages for certain unauthorized collection actions to $1 million and excludes such damages from gross income.