H.R. 5346: Fair and Accountable IRS Reviews Act

This bill, titled the Fair and Accountable IRS Reviews Act, proposes to modify how penalties and interest are assessed by the IRS (Internal Revenue Service) under the Internal Revenue Code of 1986. The key points of the bill are as follows:

Approval Process for Penalty Assessments

The bill specifies that no penalties can be assessed or communicated to a taxpayer unless the initial determination for such assessments is personally approved in writing by the immediate supervisor of the IRS employee making the assessment, or by a higher-level official designated by the Secretary of the Treasury.

This aims to ensure that there is a higher level of oversight and accountability before penalties are applied to taxpayers.

Definition of Immediate Supervisor

The bill includes a definition of "immediate supervisor," clarifying that this term refers to the person who the IRS employee making the determination reports to.

Effective Date

These changes will take effect for any notices issued and penalties assessed after December 31, 2025.

Summary of Impact

Overall, the bill seeks to reform the process of how the IRS can impose penalties on taxpayers, adding a layer of required supervisor approval before any penalties can be communicated. This is intended to enhance the fairness and accountability of the IRS in its dealings with taxpayers.

Relevant Companies

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