Appeals proceedings in recent years. Unfortunately, a regulatory interpretation complicated the intent of this long standing statute. Instead of adhering to the clear requirement that an agent's immediate supervisor must approve a penalty at the time of the initial determination, supervisory appeal could be obtained at any point in the process. And the term immediate supervisor was broadened. Beyond Congress's original intent. As the result, an agent could propose a penalty without prior review and later seek approval from a wide range of individuals. (00:50–01:02)
CLAIM
Asserts that supervisory approval for IRS penalties can now be obtained at any point, not just at the initial determination.
This is an excerpt from a raw transcript. The assertions have not been audited or verified. Tap the video to view the source footage and understand the context.