US HB5346

Amends Internal Revenue Code Section 6751(b)(1) to require written supervisory approval before any penalty-related communication is sent to a taxpayer, including proposed penalty adjustments

Requires the immediate supervisor of the IRS employee making the penalty determination (or a higher-level official designated by the Secretary) to personally approve the assessment in writing

Defines "immediate supervisor" as the person to whom the employee making the penalty determination directly reports

Applies to notices issued and penalties assessed after December 31, 2025

Passed the House of Representatives on December 1, 2025