,,ii  #aaith ,,congress  #b;d ,session  
,s4 #eadc  ,,in ,,the ,,senate ,,of     
,,the ,,united ,,states  ,july #bh1     
#bjbf,mr4 ,bennet introduced the        
following bill2 which was read twice and
 referred to the ,committee on ,finance 
,a ,,bill  ,to amend the ,internal      
,revenue ,code of #aihf to modify       
procedural requirements for penalties   
and disallowance periods4  #a4          
,modification of procedural requirements
 for penalties and disallowance periods 
7a7 ,in general ,section #fgea7;b7 of   
the ,internal ,revenue ,code of #aihf is
 amended-- 7#a7 by striking paragraph   
7#a7 and inserting the following3  7#a7 
,in general ,no penalty under this title
 shall be assessed1 and no disallowance 
period shall take effect1 unless-- 7,a7 
the decision 7as defined by the         
,secretary in regulations7 to apply such
 penalty or disallowance period1 as     
applicable1 is personally approved 7in  
writing on an electronic form7 by-- 7i7 
the immediate supervisor of the         

individual making such decision1 or     
7ii7 the ,internal ,revenue ,service    
,office of ,servicewide ,penalties 7or  
any successor organization71 and  7,b7  
the approval described in subparagraph  
7,a7 is obtained on or before the date  
any appealable notice is sent to the    
taxpayer regarding the application of   
such penalty or disallowance period4  1 
and  7#b7 by adding at the end the      
following3  7#c7 ,appealable notice ,for
 purposes of this subsection1 the term  
appealable notice means the first       
written notice issued to a taxpayer that
 provides the taxpayer an opportunity   
to-- 7,a7 appeal the decision to the    
,internal ,revenue ,service ,independent
 ,office of ,appeals1 or  7,b7 petition 
a ,federal court for review of the      
decision4  4  7b7 ,disallowance period  
,section #fgea of the ,internal ,revenue
 ,code of #aihf is amended by adding at 
the end the following new subsection3   
7d7 ,disallowance period  7#a7 ,in      
general ,for purposes of this section1  

the term disallowance period means--    
7,a7 with respect to any credit under   
section #bd1 the period determined under
 section #bd7;g77#a71  7,b7 with respect
 to any credit under section #be;,a1 the
 period determined under section        
#be;,a7b77#d77;,a71 and  7,c7 with      
respect to any credit under section #cb1
 the period determined under section    
#cb7k77#a74  7#b7 ,approval required for
 disallowance period automatically      
calculated through electronic means     
,with respect to the application of any 
disallowance period1 subsection         
7b77#b77;,b7 shall not apply4  4  7c7   
,effective date ,the amendments made by 
this section shall apply to notices sent
 after the date which is #ab months     
after the date of the enactment of this 
,act4  7d7 ,report ,not later than #bd  
months after the date of the enactment  
of this ,act1 and annually thereafter1  
the ,secretary of the ,treasury 7or the 
,secretary's delegate7 shall make       
publicly available a report regarding   

all penalties assessed by the ,internal 
,revenue ,service pursuant to the       
,internal ,revenue ,code of #aihf during
 the preceding calendar year1 with all  
relevant data regarding such penalties  
to be collected and reported with       
respect to-- 7#a7 every organizational  
unit of the ,internal ,revenue ,service 
that has power to assess1 abate1 or     
otherwise enforce any penalty imposed by
 the ,internal ,revenue ,service under  
the ,internal ,revenue ,code of #aihf1  
and  7#b7 the progression of such       
penalties at each step of the           
determination1 assessment1 and review   
processes1 as well as the final result  
with respect to such penalties4