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4(...continued)
(2) Reasonable administrative costs.--The term
“reasonable administrative costs” means–
(A) any administrative fees or similar
charges imposed by the Internal Revenue Service,
and
(B) expenses, costs, and fees described
in paragraph (1)(B), except that any determination
made by the court under clause (ii) or (iii)
thereof shall be made by the Internal Revenue
Service in cases where the determination under
paragraph (4)(C) of the awarding of reasonable
administrative costs is made by the Internal
Revenue Service.
Such term shall only include costs incurred on or after
whichever of the following is the earliest: (i) the
date of the receipt by the taxpayer of the notice of
the decision of the Internal Revenue Service Office of
Appeals; (ii) the date of the notice of deficiency; or
(iii) the date on which the first letter of proposed
deficiency which allows the taxpayer an opportunity for
administrative review in the Internal Revenue Service
Office of Appeals is sent.
* * * * * * *
(4) Prevailing party.--
(A) In general.–-The term “prevailing
party” means any party in any proceeding to
which subsection (a) applies * * *--
(i) which–-
(I) has substantially prevailed with
respect to the amount in controversy, or
(II) has substantially prevailed
with respect to the most significant issue or
set of issues presented, and
(ii) which meets the requirements
(continued...)
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