[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[H.R. 5346 Reported in House (RH)]

<DOC>





                                                 Union Calendar No. 272
119th CONGRESS
  1st Session
                                H. R. 5346

                          [Report No. 119-318]

 To amend the Internal Revenue Code of 1986 to reform certain penalty 
                        and interest provisions.


_______________________________________________________________________


                    IN THE HOUSE OF REPRESENTATIVES

                           September 15, 2025

 Mr. Grothman introduced the following bill; which was referred to the 
                      Committee on Ways and Means

                           September 30, 2025

               Additional sponsor: Mr. Smith of Nebraska

                           September 30, 2025

  Reported with an amendment, committed to the Committee of the Whole 
       House on the State of the Union, and ordered to be printed
 [Strike out all after the enacting clause and insert the part printed 
                               in italic]
    [For text of introduced bill, see copy of bill as introduced on 
                          September 15, 2025]


_______________________________________________________________________

                                 A BILL


 
 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.
                                                 Union Calendar No. 272

119th CONGRESS

  1st Session

                               H. R. 5346

                          [Report No. 119-318]

_______________________________________________________________________

                                 A BILL

 To amend the Internal Revenue Code of 1986 to reform certain penalty 
                        and interest provisions.

_______________________________________________________________________

                           September 30, 2025

  Reported with an amendment, committed to the Committee of the Whole 
       House on the State of the Union, and ordered to be printed