H.R. 5346

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 5346 Referred in Senate (RFS)]

<DOC>
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.

Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

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

SEC. 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.

Attest:

KEVIN F. MCCUMBER,

Clerk.