NEW REGS ON RECOVERY OF LITIGATION COSTS.

IRS An abbreviation for the Internal Revenue Service, a federal agency charged with the responsibility of administering and enforcing internal revenue laws. temporary regulations explain when making a qualified offer will result in the taxpayer being a prevailing party The litigant who successfully brings or defends an action and, as a result, receives a favorable judgment or verdict.

prevailing party n. the winner in a lawsuit. for purposes of a recovery of litigation An action brought in court to enforce a particular right. The act or process of bringing a lawsuit in and of itself; a judicial contest; any dispute.

When a person begins a civil lawsuit, the person enters into a process called litigation. costs.

In most tax litigation cases, a prevailing party may recover reasonable administrative and litigation costs. A taxpayer is considered to be the prevailing party if the liability determined by the court is equal to or less than the amount for which the taxpayer would have settled. The regulations explain the circumstances CIRCUMSTANCES, evidence. The particulars which accompany a fact.
2. The facts proved are either possible or impossible, ordinary and probable, or extraordinary and improbable, recent or ancient; they may have happened near us, or afar off; they are public or under which the making of a qualified offer will result in the taxpayer being considered a prevailing party.

To qualify as a prevailing party, taxpayers must not have unreasonably protracted pro·tract
tr.v. pro·tract·ed, pro·tract·ing, pro·tracts
1. To draw out or lengthen in time; prolong: disputants who needlessly protracted the negotiations.

2. the proceedings, and must have exhausted their administrative remedies. The IRS notes that a taxpayer qualifying as a prevailing party by reason of having made a qualified offer need not substantially prevail on either the amount in controversy or the most significant issue or set of issues presented.

A taxpayer cannot qualify as a prevailing party for having made a qualified offer if the offer resulted in a settlement.

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Title Annotation:	tax regulations
Publication:	California CPA
Article Type:	Brief Article
Geographic Code:	1USA
Date:	May 1, 2001
Words:	176
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