Plain English
GovGreed Synthesis · 2025-12-02
Fair and Accountable IRS Reviews Act This bill provides that an Internal Revenue Service (IRS) employee’s immediate supervisor for purposes of approving certain federal tax penalties is the person to whom such employee reports. The bill also provides that an immediate supervisor’s approval of certain federal tax penalties must be obtained (in writing) before any written communication related to such penalties is sent to the taxpayer. As background, current law requires that the initial determination by an IRS employee to assess certain federal tax penalties be approved (in writing) by such employee’s immediate supervisor (or a designated higher-level official). Under IRS regulations, an immediate supervisor is any individual with responsibility to review another individual’s proposed federal tax penalties (without such proposal being subject to an intermediary’s approval). The IRS regulations also establish requirements for when such approval must be obtained based on whether the federal tax penalty is subject to pre-assessment review or raised in Tax Court proceedings.
Market Impact Map
Action Timeline
2025-12-02
Received in the Senate and Read twice and referred to the Committee on Finance.
2025-12-01
Motion to reconsider laid on the table Agreed to without objection.
2025-12-01
On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H4940-4941)
2025-12-01
Passed/agreed to in House: On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H4940-4941)
2025-12-01
DEBATE - The House proceeded with forty minutes of debate on H.R. 5346.
2025-12-01
Considered under suspension of the rules. (consideration: CR H4940-4942)
2025-12-01
Mr. Smith (MO) moved to suspend the rules and pass the bill, as amended.
2025-09-30
Placed on the Union Calendar, Calendar No. 272.
2025-09-30
Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-318.
2025-09-30
Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-318.
Full Bill Text
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 CONGRESS 1st 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.
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