“A bill to amend the Internal Revenue Code of 1986 to modify procedural requirements for penalties and disallowance periods.”
No CRS summary available for this bill.
This section requires personal written approval by an IRS supervisor or the Office of Servicewide Penalties before assessing any penalty or applying a disallowance period for credits under sections 24, 25A, or 32, with approval required before the first appealable notice is sent to the taxpayer. It defines an appealable notice as the initial written notice allowing appeal to the IRS Independent Office of Appeals or petition to federal court. The changes apply to notices sent after 12 months following enactment. It also requires the Treasury Secretary to issue annual public reports detailing penalties assessed by every IRS organizational unit and their progression through determination, assessment, and review.