119-HR5346
Fair and Accountable IRS Reviews Act
Last action was on 9-30-2025
SenateCurrent status is Placed on the Union Calendar, Calendar No. 272.
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119th CONGRESS
1st Session
H. R. 5346
1. Short title2. Procedural requirements for assessment of penalties1. 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.