The intent and purpose of H. R. 3590 was not to raise revenue, it was to decrease taxes and provide payola in exchange for votes.
“SEC. 5. INCREASE IN PENALTY FOR FAILURE TO FILE A PARTNERSHIP OR S CORPORATION RETURN.
(a) In General- Sections 6698(b)(1) and 6699(b)(1) of the Internal Revenue Code of 1986 are each amended by striking `$89’ and inserting `$110’.”
The above part of HR 3590 raises revenue. It is sufficient to make the bill a revenue-raising bill for the purposes of Senate procedures.
You may not like the way they did it and I may not like the way they did it, but the Rats knew what they were doing.