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 supervisormeans, 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.