The Fair and Accountable IRS Reviews Act revises the Internal Revenue Code to strengthen oversight of penalty assessments . Under the new rule, no penalty may be imposed or entered into the taxpayer’s record unless the initial determination is personally approved in writing by the employee’s immediate supervisor . This requirement applies before any written communication, including a proposed penalty adjustment, is sent to the taxpayer. The amendment is intended to reduce erroneous or premature penalties and increase accountability within the IRS. Section 2(b) adds a definition for immediate supervisor , clarifying that it refers to the person to whom the employee making the determination reports. The amendment also specifies that the supervisor must be a higher‑level official designated by the Secretary if necessary. The changes become effective for all notices and penalties issued after December 31, 2025 . By instituting a supervisory approval step, the bill seeks to improve the accuracy and fairness of IRS penalty enforcement.