This bill significantly amends the Internal Revenue Code of 1986 by modifying the procedural requirements for assessing penalties and applying disallowance periods. It mandates that no penalty or disallowance period can be assessed or take effect unless the decision is personally approved in writing by either the immediate supervisor of the individual making the decision or the Internal Revenue Service Office of Servicewide Penalties. This approval must be obtained on or before the date any appealable notice is sent to the taxpayer, which is defined as the first written notice offering an opportunity to appeal to the IRS Independent Office of Appeals or petition a Federal court. The legislation also introduces a new definition for "disallowance period," specifically linking it to periods determined for certain tax credits, including those under sections 24, 25A, and 32. These amendments will apply to notices sent 12 months after the bill's enactment. Furthermore, the bill requires the Secretary of the Treasury to make a publicly available annual report detailing all penalties assessed by the IRS, including data on the organizational units involved and the progression and final results of these penalties.
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Timeline
Introduced in Senate
Read twice and referred to the Committee on Finance.
Introduced in Senate
Read twice and referred to the Committee on Finance.
Taxation
A bill to amend the Internal Revenue Code of 1986 to modify procedural requirements for penalties and disallowance periods.
USA119th CongressS-5143| Senate
| Updated: 7/28/2026
This bill significantly amends the Internal Revenue Code of 1986 by modifying the procedural requirements for assessing penalties and applying disallowance periods. It mandates that no penalty or disallowance period can be assessed or take effect unless the decision is personally approved in writing by either the immediate supervisor of the individual making the decision or the Internal Revenue Service Office of Servicewide Penalties. This approval must be obtained on or before the date any appealable notice is sent to the taxpayer, which is defined as the first written notice offering an opportunity to appeal to the IRS Independent Office of Appeals or petition a Federal court. The legislation also introduces a new definition for "disallowance period," specifically linking it to periods determined for certain tax credits, including those under sections 24, 25A, and 32. These amendments will apply to notices sent 12 months after the bill's enactment. Furthermore, the bill requires the Secretary of the Treasury to make a publicly available annual report detailing all penalties assessed by the IRS, including data on the organizational units involved and the progression and final results of these penalties.