IRS Accountability and Taxpayer Protection Act

Requires an immediate supervisor’s written, personal approval before the IRS may assess a penalty or cause a tax-credit disallowance period to begin. It defines what counts as the "initial determination," creates a new statutory definition of "disallowance period" tied to specific credit rules, sets a rule about when notices take effect, and directs the Secretary of the Treasury to publish yearly reports on penalties that begin within 24 months of enactment.