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4(...continued)
(iii) Special rules.-–If this
subparagraph applies to any court proceeding–
* * * * * * *
(II) reasonable administrative and
litigation costs shall only include
costs incurred on and after the date of
such offer.
(iv) Coordination.--This subparagraph
shall not apply to a party which is a
prevailing party under any other provision of
this paragraph.
* * * * * * *
(5) Administrative proceedings.–-The term
“administrative proceeding” means any procedure or
other action before the Internal Revenue Service.
(6) Court proceedings.–-The term “court
proceeding” means any civil action brought in a court
of the United States (including the Tax Court * * *).
(7) Position of the United States.–-The term
“position of the United States” means–-
(A) the position taken by the United States
in a judicial proceeding to which subsection (a)
applies, and
(B) the position taken in an administrative
proceeding to which subsection (a) applies as of
the earlier of--
(i) the date of the receipt by the
taxpayer of the notice of the decision of the
Internal Revenue Service Office of Appeals,
or
(ii) the date of the notice of
deficiency.
(continued...)
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Last modified: May 25, 2011