H.R. 5346House119th Congress (2025-2027)Passed House

Fair and Accountable IRS Reviews Act

Introduced September 15, 2025

AI-Generated Summary

Updated December 4, 2025 at 9:14 AM UTC

The Fair and Accountable IRS Reviews Act changes the tax code so that any IRS penalty cannot be assessed or communicated to a taxpayer unless a supervisor personally approves it in writing. The rule adds a definition of “immediate supervisor” and applies to all penalty notices issued after Dec. 31, 2025. It is intended to make penalty assessments more transparent and accountable for taxpayers.

Key Provisions

  • Requires written approval from the employee’s immediate supervisor (or a higher official designated by the Secretary) before any penalty is assessed or a penalty proposal is sent to a taxpayer.
  • Adds a definition of “immediate supervisor” as the person to whom the employee making the determination reports.
  • Applies the new approval requirement to all penalty notices and assessments issued after December 31, 2025.

Legislative Activity

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12 earlier actions
SenateIntro Referral Latest Action

Received in the Senate and Read twice and referred to the Committee on Finance.

December 2, 2025

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HouseIntro Referral

Introduced in House

September 15, 2025

HouseIntro Referral

Referred to the House Committee on Ways and Means.

September 15, 2025

HouseCommittee

Committee Consideration and Mark-up Session Held

September 17, 2025

HouseCommittee

Ordered to be Reported in the Nature of a Substitute (Amended) by the Yeas and Nays: 44 - 0.

September 17, 2025

HouseCommittee

Reported (Amended) by the Committee on Ways and Means. H. Rept. 119-318.

September 30, 2025

HouseCalendars

Placed on the Union Calendar, Calendar No. 272.

September 30, 2025

HouseFloor

Mr. Smith (MO) moved to suspend the rules and pass the bill, as amended.

December 1, 2025 • 5:19 PM

HouseFloor

Considered under suspension of the rules. (consideration: CR H4940-4942)

December 1, 2025 • 5:19 PM

HouseFloor

DEBATE - The House proceeded with forty minutes of debate on H.R. 5346.

December 1, 2025 • 5:19 PM

HouseFloor

Passed/agreed to in House: On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H4940-4941)

December 1, 2025 • 5:28 PM

HouseFloor

On motion to suspend the rules and pass the bill, as amended Agreed to by voice vote. (text: CR H4940-4941)

December 1, 2025 • 5:28 PM

HouseFloor

Motion to reconsider laid on the table Agreed to without objection.

December 1, 2025 • 5:28 PM

SenateIntro Referral

Received in the Senate and Read twice and referred to the Committee on Finance.

December 2, 2025

Floor Debate

9 members

What members said about H.R. 5346 on the floor

6 Republicans3 Democrats
Sean Casten
Rep. Sean CastenD-IL-6 · Dec 1, 2025

Mr. Speaker, I also rise in support of H.R. 4429, the Developing and Empowering our Aspiring Leaders Act, or DEAL Act, which is a critical bill to support innovation, entrepreneurship, and capital…

Ann Wagner
Rep. Ann WagnerR-MO-2 · Dec 1, 2025

Mr. Speaker, I thank my friend from Ohio for yielding. Mr. Speaker, I am proud to sponsor H.R. 4429, the Developing and Empowering our Aspiring Leaders, or DEAL, Act. This bill, which passed with…

Jason Smith
Rep. Jason SmithR-MO-8 · Dec 1, 2025

Mr. Speaker, I move to suspend the rules and pass the bill (H.R. 5346) to amend the Internal Revenue Code of 1986 to reform certain penalty and interest provisions, as amended. Mr. Speaker, I ask…

Terri A. Sewell
Rep. Terri A. SewellD-AL-7 · Dec 1, 2025

Mr. Speaker, I yield myself such time as I may consume. Mr. Speaker, I rise in support of H.R. 5346, the Fair and Accountable IRS Reviews Act. Mr. Speaker, I thank Chairman Jason Smith for putting…

Bryan Steil
Rep. Bryan SteilR-WI-1 · Dec 1, 2025

Mr. Speaker, I thank my colleague Mr. Davidson for his broad work in the capital market space and for leading us here on the floor today. I rise to urge my colleagues to support the Expanding WKSI…

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Maxine Waters
Rep. Maxine WatersD-CA-43 · Dec 1, 2025

Mr. Speaker, I yield myself such time as I may consume. Mr. Speaker, I rise today in support of H.R. 4430, which expands the number of public companies that can qualify as a well-known seasoned…

Glenn Grothman
Rep. Glenn GrothmanR-WI-6 · Dec 1, 2025

Mr. Speaker, I thank the previous speakers for their kind words and assistance on this bill. I also will address the Fair and Accountable IRS Reviews Act. For decades, Federal laws required that…

Warren Davidson
Rep. Warren DavidsonR-OH-8 · Dec 1, 2025

Mr. Speaker, I move to suspend the rules and pass the bill (H.R. 4429) to require the Securities and Exchange Commission to revise the definition of a qualifying investment, for purposes of the…

Maxine Waters
Rep. Maxine WatersD-CA-43 · Dec 1, 2025

Mr. Speaker, I yield myself such time as I may consume. I rise in support of H.R. 4431, the Improving Capital Allocation for Newcomers Act of 2025, or ICAN Act, offered by Mr. Timmons and Ms.…

Warren Davidson
Rep. Warren DavidsonR-OH-8 · Dec 1, 2025

Mr. Speaker, I move to suspend the rules and pass the bill (H.R. 4431) to amend the Investment Company Act of 1940 with respect to the definition of qualifying venture capital funds, and for other…

Warren Davidson
Rep. Warren DavidsonR-OH-8 · Dec 1, 2025

Mr. Speaker, I move to suspend the rules and pass the bill (H.R. 4430) to lower the aggregate market value of voting and non- voting common equity necessary for an issuer to qualify as a well-known…

William R. Timmons IV
Rep. William R. Timmons IVR-SC-4 · Dec 1, 2025

Mr. Speaker, I rise for my bill, H.R. 4431, the Improving Capital Allocation for Newcomers Act, also known as the ICAN Act. I am proud to partner with my colleague Representative Brittany Pettersen…

Maxine Waters
Rep. Maxine WatersD-CA-43 · Dec 1, 2025

Mr. Speaker, I yield 3 minutes to the gentleman from Illinois (Mr. Casten), who is also the vice ranking member of the Committee on Financial Services. Mr. Speaker, I yield myself the balance of my…

Bill Text

4 versions available

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Latest
Referred in SenateIssued December 2, 2025

IIB

119th CONGRESS

1st Session

H. R. 5346

IN THE SENATE OF THE UNITED STATES

December 2, 2025

Received; read twice and referred to the Committee on Finance

AN ACT

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


1.

Short title

This Act may be cited as the Fair and Accountable IRS Reviews Act.

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 (including proposal of a penalty as an adjustment) is sent to the taxpayer, the initial determination of such assessment is personally approved (in writing) by the immediate supervisor of the individual making such determination or such higher level official as the Secretary 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 determination 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.

Passed the House of Representatives December 1, 2025.

Kevin F. McCumber,

Clerk.