S.2358

IRS Accountability and Taxpayer Protection Act amends Internal Revenue Code to modify procedural rules for penalties.

The IRS Accountability and Taxpayer Protection Act amends the Internal Revenue Code to modify procedural rules for penalties. It requires that no penalty or disallowance period can be assessed unless the initial determination is personally approved by the immediate supervisor of the individual making the determination. This approval must be obtained in writing before any notice is sent to the taxpayer. The bill also mandates that requests or inquiries from the Secretary are not considered initial determinations unless they offer a specific penalty amount or disallowance period.