# 119-s-2358: IRS Accountability and Taxpayer Protection Act

119-s-2358, IRS Accountability and Taxpayer Protection Act, is a 119th Congress bill sponsored by Sen. Scott, Tim [R-SC] (R-SC); status introduced; PRIA reads it as touching household money (as of 2025-12-21).

- Canonical: https://policyrisk.com/legislation/119-s-2358
- As of: 2025-12-21
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Bill: 119-s-2358
- Congress: 119
- Title: IRS Accountability and Taxpayer Protection Act
- Status: introduced
- Introduced: 2025-07-21
- Sponsor: Sen. Scott, Tim [R-SC] (R-SC)
- Cosponsors: 6
- Policy area: Taxation
- Touches household money: yes
- Last recorded action: 2025-12-21

## Summary

**Tightens oversight of IRS penalty decisions and forces public penalty reporting.** This bill would require written, immediate-supervisor approval before the IRS sends penalty or credit-disallowance notices and would define when a notice becomes an initial determination. - Families and low-income workers would see explicit rules for credit disallowance timing. The bill ties disallowance periods to the child tax credit (section 24), the education credit (section 25A), and the Earned Income Tax Credit (section 32). - Taxpayers would gain a procedural protection. Any initial determination to impose a specific penalty amount or a specific disallowance period must be personally approved in writing by the immediate supervisor on or before the date a notice is sent, and routine requests or inquiries generally do not count as initial determinations unless they include a firm penalty offer. - IRS staff and the public would face new obligations and transparency. The bill exempts automatically calculated electronic disallowance periods from the timing rule, and it requires Treasury to publish a detailed public report on all penalties no later than 24 months after enactment and annually thereafter, showing each unit's penalty actions from start to finish.

## Cosponsors (6)

- Sen. Lummis, Cynthia M. [R-WY] (R-WY), 2025-07-21T00:00:00.000Z
- Sen. Tillis, Thomas [R-NC] (R-NC), 2025-07-21T00:00:00.000Z
- Sen. Grassley, Chuck [R-IA] (R-IA), 2025-07-21T00:00:00.000Z
- Sen. Barrasso, John [R-WY] (R-WY), 2025-07-21T00:00:00.000Z
- Sen. Crapo, Mike [R-ID] (R-ID), 2025-07-21T00:00:00.000Z
- Sen. Risch, James E. [R-ID] (R-ID), 2025-07-21T00:00:00.000Z

## Provisions PRIA read

- Supervisor sign-off before penalties: benefit, medium. This bill would require an IRS supervisor to personally sign a written approval before the IRS can assess a penalty or start a disallowance period. The written approval must be by the immediate supervisor of the official making the determination. The approval must be obtained on or before the date…
- Annual public IRS penalty reports: benefit, medium. This bill would require the Treasury Secretary to publish a public report on every IRS penalty each year. The first report would be due no later than 24 months after enactment, and then every year. The report must show data for each IRS unit with penalty authority and track each penalty from determ…
- New rules for tax-credit disallowances: mixed, medium. This bill would define when an IRS written notice becomes an "initial determination" for penalties and credit disallowances. Routine IRS questions would generally not count unless they offer a specific penalty amount or a specific disallowance period. It would say which legal time windows the IRS m…

## Related bills

- 119-s-401: Fair Access to Banking Act
- 119-s-587: Death Tax Repeal Act of 2025
- 119-s-186: No Taxpayer Funding for Abortion and Abortion Insurance Full Disclosure Act of 2025
- 119-s-6: Born-Alive Abortion Survivors Protection Act
- 119-s-3366: Back the Blue Act of 2025
- 119-s-128: SAVE Act

## Sources
- [119-s-2358 on Congress.gov](https://www.congress.gov/bill/119th-congress/senate-bill/2358)

## Related
- [119-s-401: Fair Access to Banking Act](https://policyrisk.com/legislation/119-s-401)
- [119-s-587: Death Tax Repeal Act of 2025](https://policyrisk.com/legislation/119-s-587)
- [119-s-186: No Taxpayer Funding for Abortion and Abortion Insurance Full Disclosure Act of…](https://policyrisk.com/legislation/119-s-186)
- [119-s-6: Born-Alive Abortion Survivors Protection Act](https://policyrisk.com/legislation/119-s-6)
- [119-s-3366: Back the Blue Act of 2025](https://policyrisk.com/legislation/119-s-3366)
- [119-s-128: SAVE Act](https://policyrisk.com/legislation/119-s-128)
- [All bills in Congress](https://policyrisk.com/legislation)

Source: PRIA, https://policyrisk.com/legislation/119-s-2358 (as of 2025-12-21).