US SB2358

Requires written supervisory approval before the IRS can assess any penalty or impose a disallowance period, with approval obtained before any notice is sent to the taxpayer

Defines "initial determination" as the first written notice to a taxpayer specifying a penalty amount or disallowance period based on specific facts, excluding general requests or inquiries

Applies supervisory approval requirements to credit disallowance periods under sections 24 (Child Tax Credit), 25A (education credits), and 32 (Earned Income Tax Credit), including those calculated automatically through electronic means

Mandates the Treasury Secretary publish annual reports beginning 24 months after enactment detailing all IRS penalties assessed, broken down by organizational unit and tracking penalties through determination, assessment, and review processes

Applies to notices sent after the date of enactment