- 11 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011