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119 HR 5346 : Fair and Accountable IRS Reviews Act U.S. House of Representatives 2025-12-02 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. IIB 119th CONGRESS 1st Session H. R. 5346 IN THE SENATE OF THE UNITED STATES December 2, 2025 Received; read twice and referred to the Committee on Finance 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.
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