HR 5346 United States House · 119th Congress

Fair and Accountable IRS Reviews Act

This bill requires IRS employees to obtain written approval from a supervisor before sending any penalty notice to a taxpayer. It modifies the Internal Revenue Code to mandate that an IRS official’s immediate supervisor (the person they report to) must personally approve penalty assessments in writing before any penalty communication is sent. The rule applies to all penalties issued after December 31, 2025. This directly affects taxpayers who face IRS penalty notices, adding a review step before penalties are formally proposed or imposed.

Bill status passed 3 of 5 stages cleared

Introduction

Sep 2025

Committee Review

Dec 2025

House Passage

Dec 2025

Senate Passage

President

Introduced Sep 15, 2025 Last action Dec 2, 2025

Maddy AI version diff · 1 comparison

What changed between versions

Introduced in House → Engrossed in House · 2 edits · Dec 1, 2025

MINOR

The Engrossed version of HR 5346 makes primarily formatting and structural corrections compared to the Introduced version. The one substantive change is in the effective date provision, where 'this subsection' was corrected to 'this section,' ensuring the December 31, 2025 effective date applies to all amendments in Section 2 (both the approval requirement and the immediate supervisor definition) rather than just the subsection containing the effective date language.

TECHNICAL

In the effective date provision (Section 2(c)), the reference was changed from 'this subsection' to 'this section,' broadening the scope of the effective date to cover all amendments made by Section 2 rather than just the subsection where the effective date appears.

Formatting and indentation were reorganized throughout the bill, including removal of extra blank lines and adjustment of spacing around section headings. These changes do not alter the substance of the legislation.

Floor votes

How they voted

This bill passed the House by voice vote (no roll call recorded).

Full legislative history

Actions timeline

Total actions

Key actions

Committee

Amendments

Dec 2, 2025

Committee

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

upper

Dec 1, 2025

Introduced

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

lower

Dec 1, 2025

Lower · Passed

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)

lower

Dec 1, 2025

Introduced

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

lower

Sep 30, 2025

Lower · Passed

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

lower

Sep 17, 2025

Introduced

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

lower

Sep 17, 2025

Lower · Passed

Committee Consideration and Mark-up Session Held

lower

Sep 15, 2025

Committee

Referred to the House Committee on Ways and Means.

lower

Sep 15, 2025

Introduced

Introduced in House

lower

1 primary · 1 co-sponsor