IB 
Union Calendar No. 272 
119TH CONGRESS 
1ST SESSION H. R. 5346 
[Report No. 119–318] 
To amend the Internal Revenue Code of 1986 to reform certain penalty 
and interest provisions. 
IN THE HOUSE OF REPRESENTATIVES 
SEPTEMBER 15, 2025 
Mr. GROTHMAN introduced the following bill; which was referred to the 
Committee on Ways and Means 
SEPTEMBER 30, 2025 
Additional sponsor: Mr. SMITH of Nebraska 
SEPTEMBER 30, 2025 
Reported with an amendment, committed to the Committee of the Whole 
House on the State of the Union, and ordered to be printed 
[Strike out all after the enacting clause and insert the part printed in italic] 
[For text of introduced bill, see copy of bill as introduced on September 15, 2025] 
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A BILL 
To amend the Internal Revenue Code of 1986 to reform 
certain penalty and interest provisions. 
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Be it enacted by the Senate and House of Representa-
tives 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 (includ-
ing proposal of a penalty as an adjustment) is sent 
to the taxpayer, the initial determination of such as-
sessment is personally approved (in writing) by the 
immediate supervisor of the individual making such 
determination or such higher level official as the Sec-
retary 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 supervisor’ 
means, with respect to an individual making a deter-
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mination 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. 
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Union Calendar No. 272 
119TH CONGRESS 
1ST SESSION 
H. R. 5346 
[Report No. 119–318] 
A BILL 
To amend the Internal Revenue Code of 1986 to 
reform certain penalty and interest provisions. 
SEPTEMBER 30, 2025 
Reported with an amendment, committed to the Com-
mittee of the Whole House on the State of the Union, 
and ordered to be printed 
VerDate Sep 11 2014 
22:31 Sep 30, 2025
Jkt 059200
PO 00000
Frm 00006
Fmt 6651
Sfmt 6651
E:\BILLS\H5346.RH
H5346
kjohnson on DSK7ZCZBW3PROD with $$_JOB