HR5346-119

Passed House

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

119th Congress Introduced Sep 15, 2025

Legislative Progress

Passed House
Introduced Committee Passed
Dec 2, 2025

Received; read twice and referred to the Committee on Finance

Dec 2, 2025 (inferred)

Passed House (inferred from eh version)

Sep 30, 2025

Additional sponsor: Mr. Smith of Nebraska

Sep 30, 2025

Reported with an amendment, committed to the Committee of the …

Sep 15, 2025

Mr. Grothman introduced the following bill; which was referred to …

Summary

What This Bill Does
This bill tightens IRS penalty procedures by requiring supervisor approval before any penalty-related communication is sent to taxpayers. Under current law, supervisors must approve penalties before assessment, but this bill moves that requirement earlier—before any written notice about the penalty reaches the taxpayer.

Who Benefits and How
All taxpayers benefit from increased procedural protections. When the IRS proposes a penalty, a supervisor must now sign off before the taxpayer even receives the initial letter. Tax professionals and their clients gain leverage because improperly approved penalties can be challenged. Individual taxpayers facing audits get an additional check against arbitrary penalty assessments.

Who Bears the Burden and How
The IRS faces increased administrative burden with this earlier approval requirement. Supervisors must personally review penalty determinations in writing before any taxpayer communication, which may slow down enforcement processes. This applies to notices issued and penalties assessed after December 31, 2025.

Key Provisions
- Requires written supervisor approval before any penalty-related communication to taxpayers
- Covers both penalty assessments and proposals of penalties as adjustments
- Defines "immediate supervisor" as the person the IRS employee directly reports to
- Effective for notices issued and penalties assessed after December 31, 2025
- Secretary of Treasury may designate a higher-level official for approvals

Model: claude-opus-4-5
Generated: Dec 26, 2025 21:39

Evidence Chain:

This summary is derived from the structured analysis below. See "Detailed Analysis" for per-title beneficiaries/burden bearers with clause-level evidence links.

Primary Purpose

Reforms IRS penalty procedures by requiring supervisor approval before any written communication about penalties is sent to taxpayers, and clarifies the definition of 'immediate supervisor'.

Policy Domains

Taxation IRS Reform Taxpayer Rights

Bill Structure & Actor Mappings

Who is "The Secretary" in each section?

Domains
Taxation Taxpayer Rights
Actor Mappings
"the_secretary"
→ Secretary of the Treasury

Key Definitions

Terms defined in this bill

1 term
"immediate supervisor" §6751(b)(3)

The person to whom the individual making the penalty determination reports

We use a combination of our own taxonomy and classification in addition to large language models to assess meaning and potential beneficiaries. High confidence means strong textual evidence. Always verify with the original bill text.

Learn more about our methodology