II 118th CONGRESS 1st Session S. 1249 IN THE SENATE OF THE UNITED STATES April 20, 2023 Mr. Scott of South Carolina (for himself, Mr. Barrasso , Mrs. Blackburn , Mr. Braun , Mr. Cotton , Mr. Crapo , Ms. Lummis , and Mr. Risch ) introduced the following bill; which was read twice and referred to the Committee on Finance A BILL To amend the Internal Revenue Code of 1986 to modify the procedural rules for penalties.

1. Short title This Act may be cited as the IRS Accountability and Taxpayer Protection Act . 2. Modification of procedural requirements for penalties under the Internal Revenue Code of 1986 (a) In general Section 6751(b)(1) of the Internal Revenue Code of 1986 is amended— (1) by striking of such assessment and inserting with respect to the application of such penalty , and (2) by adding at the end the following new sentence The approval required under the preceding sentence shall be given at a time in the pre-assessment process when such supervisor or higher level official has the discretion to give or withhold such approval. . (b) Effective date The amendments made by subsection (a) shall apply to notices issued, and offsets or defenses asserted, after the date of the enactment of this Act.