22. Department of the Treasury · Notable · Needs Congress
Reform the tax penalty system and reduce the most punitive penalties
Printed page 700 22. Department of the Treasury
“For example, interest on overpayments should be the same as interest on underpayments rather than the government receiving a higher rate, the time limit for taxpayers to sue for damages for improper collection actions should be extended, the jurisdiction of the Tax Court should be expanded, and the tax penalty system should be reformed by rationalizing the penalty structure and reducing some of the most punitive penalties.”
What has happened
- Not started
The penalty structure was not rationalized and no punitive penalty was reduced. Public Law 119-21 amends no penalty provision of subtitle F, and the one penalty bill to pass a chamber does not do what the Quote asks: H.R. 5346, the Fair and Accountable IRS Reviews Act, passed the House on 2025-12-01 and rewrites only section 6751(b), requiring an immediate supervisor's written approval before any written communication proposing a penalty. That is a procedural safeguard on assessment, not a rationalization of the penalty structure and not a reduction of any penalty amount.
No action found yet. This entry is the starting point, not a finding.
Research log
What was searched, and what didn’t count as evidence
Research notes
The H.R. 5346 reading is the leveling call on this item and is recorded in the chapter log’s Judgment calls. The bill’s official title — “To amend the Internal Revenue Code of 1986 to reform certain penalty and interest provisions” — matches the Quote’s words closely enough that title-matching alone would put this at attempted; the operative text does not support it (playbook §1.1).
Shares the cluster negative search with #1952, #1953 and #1954.
- Action
- restrict
- Object
- tax penalty structure
- ID
- 1955