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ARTICLE · 19 APRIL 2023

IRS Issues Proposed Regulations Under Section 6751(b)

Freeman Law
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In 1998, Congress sought to provide additional protections to taxpayers through passage of the Internal Revenue Service Restructuring and Reform Act (the "Act").

United StatesTax
Matthew Roberts
Matthew Roberts

When is Written Managerial Approval Required?

In 1998, Congress sought to provide additional protections to taxpayers through passage of the Internal Revenue Service Restructuring and Reform Act (the "Act"). Buried within the Act was new section 6751(b), which requires the IRS to comply with certain procedural requirements prior to making a penalty assessment against a taxpayer.1 Currently, section 6751(b) reads:

No penalty under this title shall be assessed unless the initial determination of such assessment is personally approved (in writing) by the immediate supervisor of the individual making such determination or such higher level official as the Secretary may designate.

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