119 HR 5346 EH: Fair and Accountable IRS Reviews Act U.S. House of Representatives text/xml EN Pursuant to Title 17 Section 105 of the United States Code, this file is not subject to copyright protection and is in the public domain.

IB 119th CONGRESS1st Session H. R. 5346 IN THE HOUSE OF REPRESENTATIVES AN ACT To amend the Internal Revenue Code of 1986 to reform certain penalty and interest provisions.

1.

Short title

This Act may be cited as the Fair and Accountable IRS Reviews Act.

2.

Procedural requirements for assessment of penalties

(a)

Approval of assessment

Section 6751(b)(1) of the Internal Revenue Code of 1986 is amended to read as follows: (1)

In general

No penalty under this title shall be assessed or entered unless, before any written communication with respect to such penalty (including proposal of a penalty as an adjustment) is sent to the taxpayer, the initial determination of such assessment is personally approved (in writing) by the immediate supervisor of the individual making such determination or such higher level official as the Secretary may designate.. (b)

Immediate supervisor defined

Section 6751(b) of such Code is amended by adding at the end the following new paragraph: (3)

Immediate supervisor

For purposes of this subsection, the term immediate supervisor means, with respect to an individual making a determination under paragraph (1), the person to whom such individual reports. . (c)

Effective date

The amendments made by this section shall apply to notices issued, and penalties assessed, after December 31, 2025.

Passed the House of Representatives December 1, 2025.Kevin F. McCumber,Clerk.