In this task, you are given a summary for US Congressional and California state bill, your task is to generate a Title for this bill. The preferred titles are under forty words and mention the purpose of the bill.

Small Business Penalty Fairness Act of 2009 - Amends the Internal Revenue Code to limit the penalty for failure to disclose a reportable transaction (a transaction determined by the Internal Revenue Service [IRS] as having a potential for tax avoidance or evasion) to 75% of the decrease in tax shown on the return as a result of such transaction. Sets forth a maximum penalty for failure to report a reportable transaction and a minimum and maximum penalty for failure to report a listed transaction (a transaction specifically identified by the IRS as a tax avoidance transaction).

Requires the Commissioner of Internal Revenue to report by June 1, 2010, and then annually, to Congress on penalties relating to abusive tax shelters and reportable transactions.

Extends the penalty for tendering a bad check to the Internal Revenue Service to any commercially acceptable payment instrument (including electronic payments).

Expands the continuous tax levy on payments to vendors for goods and services to include payments for all property, goods, or services.
A bill to amend the Internal Revenue Code of 1986 to modify the penalty for failure to disclose certain reportable transactions and the penalty for submitting a bad check to the Internal Revenue Service, to modify certain rules relating to Federal vendors, and for other purposes.