H.R. 5346 — what changed
Fair and Accountable IRS Reviews Act
From Introduced in House to Reported in House. 1 section amended between Introduced in House and Reported in House.
Sec. 2 Procedural requirements for assessment of penalties
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.”
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.”
changed
Effective date— The amendments made by this subsection section shall apply to notices issued, and penalties assessed, after December 31, 2025.