“(1) IN GENERAL.—No penalty under this title shall be assessed, and no disallowance period shall take effect, unless—

“(A) the decision (as defined by the Secretary in regulations) to apply such penalty or disallowance period, as applicable, is personally approved (in writing on an electronic form) by—

“(i) the immediate supervisor of the individual making such decision, or

“(ii) the Internal Revenue Service Office of Servicewide Penalties (or any successor organization), and

“(B) the approval described in subparagraph (A) is obtained on or before the date any appealable notice is sent to the taxpayer regarding the application of such penalty or disallowance period.”, and

“(3) APPEALABLE NOTICE.—For purposes of this subsection, the term ‘appealable notice’ means the first written notice issued to a taxpayer that provides the taxpayer an opportunity to—

“(A) appeal the decision to the Internal Revenue Service Independent Office of Appeals, or

“(B) petition a Federal court for review of the decision.”.

“(d) Disallowance period.—

“(1) IN GENERAL.—For purposes of this section, the term ‘disallowance period’ means—

“(A) with respect to any credit under section 24, the period determined under section 24(g)(1),

“(B) with respect to any credit under section 25A, the period determined under section 25A(b)(4)(A), and

“(C) with respect to any credit under section 32, the period determined under section 32(k)(1).

“(2) APPROVAL REQUIRED FOR DISALLOWANCE PERIOD AUTOMATICALLY CALCULATED THROUGH ELECTRONIC MEANS.—With respect to the application of any disallowance period, subsection (b)(2)(B) shall not apply.”.

“(1) IN GENERAL.—No penalty under this title shall be assessed, and no disallowance period shall take effect, unless—

“(A) the decision (as defined by the Secretary in regulations) to apply such penalty or disallowance period, as applicable, is personally approved (in writing on an electronic form) by—

“(i) the immediate supervisor of the individual making such decision, or

“(ii) the Internal Revenue Service Office of Servicewide Penalties (or any successor organization), and

“(B) the approval described in subparagraph (A) is obtained on or before the date any appealable notice is sent to the taxpayer regarding the application of such penalty or disallowance period.”, and

“(3) APPEALABLE NOTICE.—For purposes of this subsection, the term ‘appealable notice’ means the first written notice issued to a taxpayer that provides the taxpayer an opportunity to—

“(A) appeal the decision to the Internal Revenue Service Independent Office of Appeals, or

“(B) petition a Federal court for review of the decision.”.

“(d) Disallowance period.—

“(1) IN GENERAL.—For purposes of this section, the term ‘disallowance period’ means—

“(A) with respect to any credit under section 24, the period determined under section 24(g)(1),

“(B) with respect to any credit under section 25A, the period determined under section 25A(b)(4)(A), and

“(C) with respect to any credit under section 32, the period determined under section 32(k)(1).

“(2) APPROVAL REQUIRED FOR DISALLOWANCE PERIOD AUTOMATICALLY CALCULATED THROUGH ELECTRONIC MEANS.—With respect to the application of any disallowance period, subsection (b)(2)(B) shall not apply.”.