I also will address the Fair and Accountable IRS Reviews Act. For decades, Federal laws required that before the IRS can impose penalties on a taxpayer, an agent must first receive written approval from that agent's immediate supervisor. Congress put this safeguard in place to ensure that penalties are imposed fairly, consistently, and with appropriate oversight. A supervisor's signature helps prevent the use of penalties as a pressure tactic and creates a transparent record that benefits both taxpayers and the government in collection and appeals proceedings. In recent years, unfortunately, a regulatory interpretation complicated the intent of this longstanding statute. Instead of adhering to the clear requirement that an agent's immediate supervisor must approve a penalty at the time of the initial determination, supervisory appeal could be obtained at any point in the process and the term 'immediate supervisor' was broadened beyond Congress' original intent. As a result, an agent could propose a penalty without prior review and later seek approval from a wide range of individuals, weakening the transparency and accountability that the law was designed to ensure. The Fair and Accountable IRS Reviews Act restores clarity.
Editor's note · Context
Discussing the Fair and Accountable IRS Reviews Act and its impact on IRS penalty procedures.
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