4 versions

CosmeticWhat changed in REFERRED IN SENATEcompared with ENGROSSED IN HOUSE (Dec 1, 2025)

Technical corrections only. The two versions of H.R. 5346 are substantively identical, with v4 reflecting the bill's referral to the Senate and an updated attestation from the House Clerk. No policy changes were made between v3 and v4.

H.R. 5346119th CongressIntroduced Sep 15, 2025

Fair and Accountable IRS Reviews Act

Passed HouseTaxationMajor

View bill text

Sponsor: Rep. Grothman, Glenn [R-WI-6]
Committees: Finance Committee (primary)
Last action: Dec 2, 2025

Bottom line

The bill tightens procedural requirements for the IRS to assess penalties by mandating explicit supervisory approval before taxpayers are notified of a proposed penalty.

What it actually does

This bill amends Section 6751(b)(1) of the Internal Revenue Code of 1986 to require that the initial determination of any penalty assessment must be personally approved in writing by the immediate supervisor of the individual making the determination. This approval must occur before any written communication regarding the penalty is sent to the taxpayer. The bill also defines 'immediate supervisor' as the person to whom the individual making the determination reports.

Proponents argue

Proponents argue that this bill enhances taxpayer protections by ensuring that penalty assessments are not arbitrary and receive proper supervisory review before being communicated. They contend it promotes fairness and accountability within the IRS, reducing the likelihood of erroneous penalties and improving the overall integrity of the tax administration process.

Opponents contend

Opponents might argue that this measure could introduce unnecessary administrative burdens and delays into the IRS's penalty assessment process, potentially hindering efficient tax enforcement. They may contend that existing safeguards are sufficient and that adding more procedural steps could slow down collections and increase operational costs for the agency.

The bill is very short and clearly written, making it highly accessible for any reader to understand its core provisions quickly.

Section 2(a) and 2(b)

Procedural Requirements for Assessment of Penalties

prominently featuredstraightforward

This section modifies existing law to require that an IRS penalty cannot be assessed or entered unless the initial determination of that penalty is personally approved in writing by the immediate supervisor of the IRS employee making the determination. This approval must happen before any written communication about the penalty is sent to the taxpayer. It also clarifies that an 'immediate supervisor' is the person to whom the individual making the penalty determination reports.

GroupImpactMechanismScale

GroupTaxpayers facing IRS penaltiesImpactPotential benefit from increased scrutiny and review of penalty assessments, potentially reducing erroneous penalties or providing an earlier opportunity for resolution.MechanismRequires an additional layer of review and approval by a supervisor before a penalty is formally proposed or assessed.ScaleIndividual, case-by-case, but applies to all taxpayers subject to IRS penalties.

GroupInternal Revenue Service (IRS)ImpactIncreased administrative burden and procedural steps for penalty assessments, potentially leading to minor delays or increased workload for supervisors.MechanismMandates a specific written approval step by an immediate supervisor at an earlier stage of the penalty assessment process.ScaleSystemic, affecting all IRS divisions involved in penalty determinations.

Supporters argue

Supporters argue that this provision strengthens due process for taxpayers by ensuring that penalty determinations are not made unilaterally and are subject to a necessary level of internal review before impacting the taxpayer.

Critics contend

Critics might argue that this procedural change could add unnecessary bureaucracy and potentially slow down the IRS's ability to enforce tax laws and collect revenue efficiently, without a significant corresponding benefit to taxpayers.

Tradeoffs

The provision navigates the tension between enhancing taxpayer protections and ensuring efficient and timely tax administration. It aims to prevent arbitrary penalties but may introduce additional steps into an already complex process.

About this analysis. AI-Generated from the official bill text and available committee reports. Gaps in available data are noted explicitly. Verify important details with the official Congress.gov record.