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New IRS penalty assessment rules for fairer reviews

This act changes how the IRS assesses penalties, requiring written approval from a supervisor before any penalty communication is sent to a taxpayer. This aims to increase transparency and accountability in the penalty assessment process, giving citizens more assurance that decisions are thoroughly reviewed. These changes will apply from January 1, 2026.
Key points
Before an IRS penalty is assessed, the decision must be personally approved in writing by the immediate supervisor of the individual making the determination.
This approval is required before any written communication about the penalty, including a proposed adjustment, is sent to the taxpayer.
The changes are intended to ensure penalties are assessed more fairly and accountably.
These new rules will apply to notices issued and penalties assessed after December 31, 2025.
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Passed House
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Additional Information
Print number: 119_HR_5346
Sponsor: Rep. Grothman, Glenn [R-WI-6]
Process start date: 2025-09-15