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7430.5
4(...continued)
administrative costs.
5 Sec. 7430 provides, in pertinent part, as follows:
SEC. 7430 AWARDING OF COSTS AND CERTAIN FEES.
(a) In General.--In any administrative or court
proceeding which is brought by or against the United States
in connection with the determination, collection, or refund
of any tax, interest, or penalty under this title, the
prevailing party may be awarded a judgment or a settlement
for--
* * * * * * *
(2) reasonable litigation costs incurred
in connection with such court proceeding.
(b) Limitations.--
* * * * * * *
(3) Costs denied where party prevailing protracts
proceedings.--No award for reasonable litigation and
administrative costs may be made under subsection (a)
with respect to any portion of the administrative or
court proceeding during which the prevailing party has
unreasonably protracted such proceeding.
* * * * * * *
(c) Definitions.--For purposes of this section--
* * * * * * *
(4) Prevailing party.--
(A) In general.--The term “prevailing party”
means any party in any proceeding to which
subsection (a) applies * * *--
(i) which-–
(continued...)
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