H.R. 5346 · Passed House · Taxation

Fair and Accountable IRS Reviews Act

Sponsor: Glenn Grothman (R-WI)

What it does

• Defines an IRS employee's immediate supervisor, for approving certain tax penalties, as the person to whom the employee reports.
• Requires the supervisor's written approval of a penalty before any written communication about it goes to the taxpayer.
• Replaces IRS regulations that define a supervisor as anyone responsible for reviewing proposed penalties and that time approval by the type of review.

Official summary

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.

Latest action

Dec 2, 2025: Received in the Senate and Read twice and referred to the Committee on Finance.

Committee: Senate Finance