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United States · Official source
3,558 records where Rep. Crane, Philip M. [R-IL-8] is listed as a sponsor, author, or other actor. Search with topics and years
United States · United States Congress · 1 February 1977
Repeals the laws permitting the private carriage of letters. Exempts letters and packages carried by private express from the requirement that all letters and packages carried by a vessel in interstate commerce by delivered promptly to the local post office upon arrival in a port.
United States · United States Congress · 1 February 1977
Amends the Internal Revenue Code to limit the application of the Tax Reform Act's elimination of the sick pay exclusion for persons who have not retired on total disability, to taxable years beginning after December 31, 1976.
United States · United States Congress · 1 February 1977
Requests that the concerns of the United States be conveyed to the Soviet government regarding adherence to the Helsinki Declaration with respect to freedom to emigrate.
United States · United States Congress · 31 January 1977
Amends the Rules of the House of Representatives to remove the 25-member limit to the number of sponsors of any House of Representatives bill. Permits the addition or deletion of any Member's name as the sponsor of any legislation by a request made by a Member to the Speaker on behalf of such Member.
United States · United States Congress · 27 January 1977
Jobs Creation Act - Amends the Internal Revenue Code to reduce the individual income tax rates. Allows a credit against the income tax up to $1,000, for ten percent of the increase in the total savings deposits and investments since the end of the previous year. Allows a limited income tax deduction by certain domestic corporations for dividends paid. Limits corporate deductions for dividends received from foreign corporations. Repeals corporate deductions for other dividends received. Allows the taxpayer to take a deduction for specified percentages of the acquisition costs of certain types of property, with a corresponding reduction in basis, in lieu of a depreciation deduction. Doubles the corporate surtax exemption to $100,000.
United States · United States Congress · 27 January 1977
Establishes a Commission on Legislative-Judicial Relations to conduct a study of article III, section 2, of the Constitution relating to the authority of Congress to limit the appellate jurisdiction of the Supreme Court and inferior courts and other related issues. Requires the Commission to submit a report to the Congress.
United States · United States Congress · 26 January 1977
Makes it unlawful for any individual or entity to solicit to enroll or enroll any member of the armed forces in any labor organization, or for any member of the armed forces to join, or encourage other members to join, any labor union. Prescribes a penalty of not more than five years imprisonment for any individual violating this Act, and a fine of not less than $25,000 nor more than $50,000 for any labor organization in violation of this Act. (Adds 10 U.S.C. 975)
United States · United States Congress · 26 January 1977
Truth in Government Accounting Act - Requires the Secretary of the Treasury to prepare and make public annual consolidated financial statements for all expenditures of the United States utilizing the accrual method of accounting.
United States · United States Congress · 26 January 1977
Truth in Government Accounting Act - Requires the Secretary of the Treasury to prepare and make public annual consolidated financial statements for all expenditures of the United States utilizing the accrual method of accounting.
United States · United States Congress · 26 January 1977
Truth in Government Accounting Act - Requires the Secretary of the Treasury to prepare and make public annual consolidated financial statements for all expenditures of the United States utilizing the accrual method of accounting.
United States · United States Congress · 26 January 1977
Cost-of-Living Adjustment Act - Provides, under the Internal Revenue Code, for automatic cost-of-living adjustments, based on the Consumer Price Index, in: (1) the income tax rates; (2) the amount of standard deductions; (3) the amount of personal exemptions; (4) the amount of depreciation deductions; and (5) the adjusted basis for property. Makes cost-of-living adjustments in specified United States savings bonds and certificates and on other obligations of the United States.
United States · United States Congress · 26 January 1977
Cost-of-Living Adjustment Act - Provides, under the Internal Revenue Code, for automatic cost-of-living adjustments, based on the Consumer Price Index, in: (1) the income tax rates; (2) the amount of standard deductions; (3) the amount of personal exemptions; (4) the amount of depreciation deductions; and (5) the adjusted basis for property. Makes cost-of-living adjustments in specified United States savings bonds and certificates and on other obligations of the United States.
United States · United States Congress · 26 January 1977
Declares it the sense of the House of Representatives that the Government of the United States should maintain its rights and jurisdiction over the Panama Canal and the Panama Canal Zone.
United States · United States Congress · 26 January 1977
Declares it the sense of the House of Representatives that the Government of the United States should maintain its rights and jurisdiction over the Panama Canal and the Panama Canal Zone.
United States · United States Congress · 19 January 1977
Stipulates that the United States shall pay reasonable litigation costs, including attorney's fees, to any defendant in a Federal criminal case who is not convicted after trial, whose prosecution is dismissed with prejudice, or whose conviction is ultimately vitiated other than by pardon on grounds other than innocence.
United States · United States Congress · 19 January 1977
Directs the United States to pay reasonable litigation costs, including attorney fees, to prevailing defendants in civil actions in which the United States is a plaintiff.
United States · United States Congress · 13 January 1977
Directs the United States to pay reasonable litigation costs, including attorney fees, to prevailing defendants in civil actions in which the United States is a plaintiff.
United States · United States Congress · 13 January 1977
Prohibits the inspection or acquisition by an agent of the United States of medical and dental records of patients who are not under a federally- assisted program. Sets forth the procedure by which a patient may authorize the disclosure of such records. Establishes criminal penalties for violations of this Act.
United States · United States Congress · 13 January 1977
Directs the United States to pay reasonable litigation costs, including attorney fees, to prevailing defendants in civil actions in which the United States is a plaintiff.
United States · United States Congress · 12 January 1977
Expresses the sense of the Congress that all inspections under the Occupational Safety and Health Act of 1970 cease until the Supreme Court of the United States has determined the constitutionality of such inspections.
United States · United States Congress · 4 January 1977
Amends the Federal Food, Drug, and Cosmetic Act to eliminate the requirement that persons filing an application with the Secretary of Health, Education, and Welfare include as part of application for approval of a new drug full reports of investigations which show whether or not such a drug is effective. Eliminates the power of the Secretary to disapprove a new drug on the basis that such drug will not have the effect it purports or is represented to have under the conditions of use prescribed, recommended, or suggested in the proposed labeling of the drug. Prevents the Secretary from withholding exemption for an experimental drug for investigative purposes on the basis that such drug will not be effective in a research context. Eliminates the authority of the Secretary to withhold approval of an application with respect to any new animal drugs on the basis that full reports of investigations on such drug have not proven it effective. Prevents the Secretary from withdrawing approval of a new animal drug on the basis that it poses an imminent hazard to health of man or animals because of a lack of substantial evidence that the drug will have the effect it purports or is represented to have under the conditions of use prescribed, recommended, or suggested in the labeling of it.
United States · United States Congress · 30 September 1976
Comprehensive Right-to-Quality Medical Care Act - Requires that any Federal officer or agency proposing any health care regulation submit such regulation to each House of Congress together with a report containing a full explanation thereof. Allows either House of Congress to keep the proposed regulation from becoming effective by adopting a resolution disapproving the regulation because: (1) it contains provisions contrary to law; (2) it is inconsistent with the intent of Congress; or (3) it goes beyond the mandate of the legislation which it is designed to implement or in the administration of which it is designed to be used. Establishes rules for the consideration of any resolution regarding such proposed regulations. Requires the head of any Federal agency or department, at least 60 days prior to the initial publication of any health cost regulation, to submit notice of intended publication and the text of such regulation to the appropriate committees of the House of Representatives and the Senate. Amends the Social Security Act to repeal specified Medicare utilization review provisions, specified utilization review provisions and maternal and child health programs, and specified professional standards review provisions. Guarantees the confidentiality of medical records of any patient whose medical or dental care is not paid by the Federal Government, under a Federal program, or by any program receiving Federal financial assistance, unless such patient has authorized such disclosure.
United States · United States Congress · 17 September 1976
Student's Freedom of Choice Act - Amends the National Labor Relations Act to exempt full-time secondary and college students from compulsory union membership.
United States · United States Congress · 17 September 1976
Amends the National Labor Relations Act to prohibit employers from making an agreement with a labor organization which requires membership therein as a condition of employment.
United States · United States Congress · 15 September 1976
Permits the acceptance by the House of Representatives of a gift of a portrait of Leslie C. Arends of the State of Illinois, a former member. Provides that such portrait shall be displayed at a location in the United States Capitol Building, subject to approval of the Speaker of the House.
United States · United States Congress · 14 September 1976
Small Business Growth and Job Creation Act - Title I: Small Business Independence and Continuation - Amends the Internal Revenue Code to establish graduated corporate income tax rates. Changes the holding period for capital assets from six months to one year. Establishes a new alternative tax on capital gains. Increases the estate tax exemption from $60,000 to $180,000. Establishes a new rate schedule for the estate tax. Increases the gift tax exclusion from $3,000 to $9,000, and the gift tax exemption from $30,000 to $90,000. Replaces the present gift tax schedule with a flat rate of 75 percent of whatever the estate tax on such a sum would be. Provides that a distribution of property by a corporation in redemption of stock to pay death taxes shall be treated as a distribution in full payment in exchange for the stock if all of the stock of such corporation which is included in determining the value of the decedent's gross estate is either, (1) more than 20 percent (generally, 35 percent), of the value of the gross estate of such decedent, or (2) more than 40 percent (generally, 50 percent) of the taxable estate of such decedent. Provides that if stock in a corporation is sold by a shareholder owning stock representing more than 30 percent of the fair market value of all outstanding stock of the corporation whose stock is being sold, the gain from such sale shall be recognized only to the extent that the taxpayer's sale price exceeds the cost of replacement property purchased by the taxpayer within two years. Defines "replacement property" as property which is held for the production of income or which is held for investment. Allows the executor of an estate involving an interest in a closely held business to elect to include in the value of the gross estate the decedent's basis in such business rather than the fair market value of such interest. States that the basis of property acquired from a decedent as to which such an election was made shall be the decedent's basis in such property rather than the fair market value of such interest. Allows the marital deduction of the estate tax to exceed 50 percent of the value of the adjusted gross estate when an interest in a specially defined small business is included in the estate. Title II: Small Business Growth Incentives - Allows a taxpayer to choose the cash method of accounting in any case where inventory is an income determining factor and the ending inventory for the taxable year does not exceed $200,000. Provides a deferred tax credit against taxable income for unincorporated businesses. Establishes a graduated investment tax credit. Amends the definition of a small business corporation to allow domestic corporations with up to 20 shareholders (presently, ten) to qualify for subchapter S treatment. Allows a small business to make a subchapter S election at any time during the taxable year. Allows to a business a credit equal to 50 percent of the wages paid during the taxable year to new employees, up to two employees and $20,000 for the taxable year. Allows a similar credit for new disadvantaged employees up to a maximum of $60,000 per taxable year. Allows the practical cost recovery method to be used in computing depreciation. Title III: Small Business Tax Simplification - Allows a corporation to file an application for refund of overpayment of estimated income tax at any time during the taxable year. Provides a special rule for treatment of net operating loss adjustments in the case of new corporations. Increases the minimum credit on accumulated earnings from $150,000 to $500,000. Redefines "section 1244 stock" to mean common stock in a corporation if: (1) such corporation during its preceding taxable year derived more than 50 percent of its aggregate gross receipts from sources other than royalties, rents, dividends, interest, annuities, and sales or exchanges of stock or securities; and (2) the equity capital of such corporation does not exceed $1,000,000. Increases the losses on section 1244 stock which may be treated as ordinary losses (rather than capital losses) from $25,000 to $50,000.
United States · United States Congress · 2 September 1976
Expresses the sense of the House of Representatives that the President shall submit a full report to Congress on fundamental human rights and cultural freedoms in Romania with special emphasis on the national minorities, showing concrete measures taken to ameliorate their situation by the Romanian Government. Directs that should no ameliorative measures occur, it is the sense of the House that the 1975 United States-Romanian Trade Agreement and the most-favored-nation treatment of the Socialist Republic of Romania shall not be extended.
United States · United States Congress · 31 August 1976
Regulatory Cost Impact Act - Requires every Federal agency to prepare in conjunction with every regulation it proposes which may have a significant impact on costs to the public a Regulatory Cost/Benefit Assessment setting forth the foreseeable costs and benefits of and alternatives to such regulation. Requires that hearings on such regulations include comments solicited from the public, Federal, State, and local agencies on the final wording of such cost/benefit assessment. Provides special procedures for emergency regulations which must be promulgated immediately to protect the public. Requires each committee of Congress which reports legislation which may have a significant impact on costs to the public to prepare a Regulatory Cost/Benefit Assessment.
United States · United States Congress · 31 August 1976
Truth in Government Accounting Act - Requires the Secretary of the Treasury to prepare and make public annual consolidated financial statements for all expenditures of the United States utilizing the accrual method of accounting.
United States · United States Congress · 31 August 1976
Amends the Federal Aviation Act of 1958 to direct the Civil Aeronautics Board, in the exercise and performance of its powers and duties, to consider the necessity of maximum competitive market forces to provide the needed air transportation system. Establishes time limitations in which the Board is required to determine applications for certificates of public convenience and necessity. Directs the Board to issue such certificate as requested if it does not act within such period. Directs the Board to issue a certificate of public convenience and necessity to qualified applicants for service between any two cities not receiving non-stop scheduled air transportation. States that air carriers which engage in interstate air commerce solely with aircraft having a capacity of less than 56 passengers or 16,000 pounds of property shall not be required to obtain such a certificate. Requires the Board to reissue all certificates for interstate air transportation by January 1, 1981, in the form of an unduplicated list of city pairs that each air carrier is authorized to serve. Authorizes carriers to transfer, sell, or lease any or all of its authority to engage in interstate air transportation. Requires the Board to approve such transaction unless it fails to meet specified standards. Permits air carriers to abandon routes under specified conditions. Allows carriers engaged in interstate or foreign air transportation to engage in non-stop transportation without regard to any certificate limitations between any points in the United States named in its certificate. Directs the Board to undertake proceedings to eliminate certificate restrictions which preclude such non-stop service. Directs the Board to establish new classes of scheduled passenger air carriers based on criteria relating to the number of available seat miles. Allows air carriers which hold a certificate of public convenience and necessity and air carriers holding a certificate issued by a State regulatory authority which report their available seat miles to engage in interstate scheduled air transportation in additional markets to those otherwise authorized subject to specified regulations. Allows air carriers engaged in non-stop scheduled air transportation between two points to apply for a certificate authorizing unrestricted non-stop service in such market. Requires the Board to grant such application within 30 days unless the applicant has not conformed with the provisions of this Act. Repeals the Postmaster General's authority to require an air carrier to establish additional schedules for the transportation of mail between two points served by such carrier. Requires persons seeking approval of a consolidation, merger, or acquisition of an air carrier to file a copy of such proposal with the Attorney General and Secretary of Transportation in addition to the Board. Prohibits the Board from granting such request if it would result in a restraint of trade unless the anticompetitive effects of such proposal are outweighed by its probable effect in meeting the transportation needs of the communities involved and such needs cannot be satisfied by a lesser anticompetitive alternative. Authorizes the Attorney General to bring an antitrust action concerning such transaction. Prohibits the consummation of such transaction until the antitrust action has been completed. Requires the Board to notify the Attorney General and Secretary of Transportation of any pooling agreements between air carriers. Requires the Board to conduct a hearing regarding such proposal or an already existing agreement which may have anticompetitive implications or fails to serve a transportation need upon the request of the Secretary or Attorney General. Prohibits the Board from approving specified types of contracts or agreements in interstate or overseas air transportation. States that the Board may not find an air carrier rate which is above direct costs as unjust or unreasonable on the basis that it is too low. Prohibits the Board from requiring an air carrier to charge a rate in excess of the direct costs of such service. Directs the Board to consider criteria in determining the maximum rates for air transportation. Allows the temporary suspension of proposed air carrier rates by the Board when the lawfulness of such rate change has be challenged. Requires the Board to complete the proceedings regarding such challenged rate change within 180 days of the time when such change would have gone into effect. Authorizes the Postal Service, upon a determination that the service provided by certified air carriers between any two points is inadequate for its needs, to contract with other air carriers for the transportation of mail between such points. Directs the Secretary of Transportation to conduct a study of the local air carrier subsidy program and to make recommendations to Congress for any necessary changes in such system.
United States · United States Congress · 31 August 1976
Repeals provisions specifying restrictions on, and requirements for, the private carriage of letters. Eliminates criminal penalties for such carriage.
United States · United States Congress · 31 August 1976
Authorizes the Secretary of the Army, acting through the Chief of Engineers, to implement a five-year demonstration program to increase the average annual diversion of water from Lake Michigan.
United States · United States Congress · 4 August 1976
Comprehensive Right-to-Quality Medical Care Act - Requires that any Federal officer or agency proposing any health care regulation submit such regulation to each House of Congress together with a report containing a full explanation thereof. Allows either House of Congress to keep the proposed regulation from becoming effective by adopting a resolution disapproving the regulation because: (1) it contains provisions contrary to law; (2) it is inconsistent with the intent of Congress; or (3) it goes beyond the mandate of the legislation which it is designed to implement or in the administration of which it is designed to be used. Establishes rules for the consideration of any resolution regarding such proposed regulations. Requires the head of any Federal agency or department, at least 60 days prior to the initial publication of any health cost regulation, to submit notice of intended publication and the text of such regulation to the appropriate committees of the House of Representatives and the Senate. Amends the Social Security Act to repeal specified Medicare utilization review provisions, specified utilization review provisions and maternal and child health programs, and specified professional standards review provisions. Guarantees the confidentiality of medical records of any patient whose medical or dental care is not paid by the Federal Government, under a Federal program, or by any program receiving Federal financial assistance, unless such patient has authorized such disclosure.
United States · United States Congress · 3 August 1976
Commends the government and commando units of Israel for the rescue mission at Entebbe Airport. Disapproves efforts being undertaken by certain nations to condemn or censure Israel for such mission. Supports the United States-United Kingdom position at the United Nations condemning all acts of terrorism. Requests the President to engage in the negotiation of agreements with other nations to help prevent acts of terrorism.
United States · United States Congress · 29 July 1976
Amends Title II (Old-Age, Survivors, and Disability Insurance) of the Social Security Act to guarantee the social security coverage of policemen's and firemen's positions covered by the Illinois Municipal Retirement Fund. States that such coverage shall apply to all services performed prior to July 1, 1976.
United States · United States Congress · 28 July 1976
Amends the Occupational Safety and Health Act of 1970 to provide that any employer who successfully contests a citation or penalty under such Act shall be awarded a reasonable attorney's fee and other reasonable litigation costs.
United States · United States Congress · 30 June 1976
Authorizes and requests the President to designate the 2nd day of July, 1976, as "Bicentennial Day of Prayer of Thanksgiving and Guidance."
United States · United States Congress · 24 June 1976
Entitles all persons sustaining damage as a result of the collapse of the Teton Dam on the Teton River, Idaho, to receive full compensation from the United States as determined by the Secretary of the Interior or his designee in accordance with the laws of the State of Idaho. Stipulates that acceptance of any award made under this Act shall constitute a complete release of all claims of the claimant arising from the dam collapse. Directs the Secretary to enter into agreements with the owner of irrigation facilities damaged by the dam collapse to finance the repair or reconstruction of such facilities. Permits claimants aggrieved by a decision by the Secretary under this Act to appeal the decision to the United States District Court for the District of Idaho.
United States · United States Congress · 24 June 1976
Expresses the sense of Congress that the Soviet Union should release Georgi Vins from imprisonment and allow freedom of religion in that nation.
United States · United States Congress · 23 June 1976
Establishes in the House of Representatives a select committee to be known as the Select Committee on Narcotics Abuse and Control. Provides that the select committee shall conduct a continuing comprehensive study and review of the problems of narcotics abuse and control and shall review any recommendations made by the President, or by any department or agency of the executive branch of the Federal Government, relating to programs or policies affecting narcotics abuse or control. Authorizes the select committee to conduct field investigations or inspections. Requires the select committee to submit an annual report to the House which shall include a summary of the activities of the select committee during the calendar year to which such report applies.
United States · United States Congress · 17 June 1976
International Social Security Agreements Act - Authorizes the President, under Title II (Old-Age, Survivors and Disability Insurance) of the Social Security Act, to enter into agreements establishing arrangements between the social security system of the United States and the social security system of any foreign country, for the purpose of establishing entitlement to and the amount of old-age, survivors, disability, or derivative benefits based on a combination of an individual's periods of coverage under the social security system established by this title and the social security system of such foreign country. Sets forth regulations governing the apportionment of benefits and the crediting of coverage based on periods of coverage in this country and a foreign country. Amends the Internal Revenue Code to prevent the withholding of social security taxes from an individual during any period when such individual's income is subject to the social security taxes of another country.
United States · United States Congress · 16 June 1976
Eliminates the requirement, under the Federal Food, Drug, and Cosmetic Act, that new drugs be regulated according to their effectiveness. States that such drugs be regulated solely to assure their safety.
United States · United States Congress · 11 June 1976
Repeals provisions specifying restrictions on, and requirements for, the private carriage of letters. Eliminates criminal penalties for such carriage.
United States · United States Congress · 8 June 1976
Requires the United States to pay to any defendant who prevails in a civil action in which the United States is a plaintiff a reasonable attorney's fee and other reasonable litigation costs.
United States · United States Congress · 3 June 1976
Provides that funds shall not be expended from the contingent fund of the House of Representatives for allowances to Members, officers, or standing committees of the House except through the adoption of a resolution by the House of Representatives.
United States · United States Congress · 17 May 1976
Directs the Secretary of Defense to furnish to the House of Representatives information available to him relative to the extent of Cuban or other foreign military or paramilitary presence in the Republic of Panama or in the Panama Canal Zone.
United States · United States Congress · 13 May 1976
Eliminates the requirement, under the Federal Food, Drug, and Cosmetic Act, that new drugs be regulated according to their effectiveness. States that such drugs be regulated solely to assure their safety.
United States · United States Congress · 12 May 1976
Broadened Stock Ownership Act - Provides that for purposes of the Internal Revenue Code the term "broadened stock ownership plan" means a trust created or organized in the United States for the exclusive benefit of an individual or his beneficiaries which meets specified requirements, including: (1) contributions will not be accepted for the taxable year in excess of $1,500 on behalf of any individual; (2) the trust is designed to invest solely in common stock of domestic corporations; (3) contributions received by the trustee during a particular taxable year will be allocated to a separate class year account; and (4) the interest of an individual in each class year account may not be paid or distributed before the end of the seventh taxable year following that year in which such class year account was established, except in the case of death or disability. States that the term "broadened stock ownership annuity" means a contract for a variable annuity, issued by an insurance company which meets specified requirements similar to those of the stock ownership trust above. Provides that a trust created or organized in the United States by an employer for the exclusive benefit of his employees or their beneficiaries, or by an association of employees for the exclusive benefit of its members or their beneficiaries, shall be treated as a broadened stock ownership, but only if the trust meets the requirements of such a plan as stated above and also provides a separate accounting for the interest of each employee or member. Exempts broadened stock ownership plans from taxation. Provides that any amount paid by an employer to a broadened stock, ownership plan or annuity shall be included in an individuals gross income. Allows an individual to deduct from his gross income amounts paid in cash during the taxable year by or on behalf of such individual to a broadened stock ownership plan or annuity. Stipulates that no deduction shall be allowed for the two taxable years succeeding the taxable year in which a payment or distribution from such a plan or annuity which is taxable to the individual under this Act is made. Stipulates that the deduction allowable to an individual under this Act may not exceed an amount equal to 15 percent of the compensation included in his gross income for such taxable year, or $1,500, whichever is less, multiplied by a fraction, the denominator of which is $20,000 and the numerator of which is $20,000 minus the excess of such compensation over $20,000. Provides that any amount received from a class year account established more than seven years before the taxable year in which the amount is received, and any amount paid or distributed on account of the death of the individual for whose benefit the broadened stock ownership plan or annuity was created, shall be included in gross income in the year received and treated as a long term capital gain. Makes technical and conforming amendments to the Internal Revenue Code.
United States · United States Congress · 11 May 1976
Emergency Food Stamp Vendor Accountability Act - Directs the Secretary of Agriculture, under the Food Stamp Act of 1964, to prescribe regulations to be followed by food coupon vendors or any officers, employees, or agents thereof with respect to the depositing of funds received for such coupons and the accounting for such funds to the State and Federal Government. Requires vendors to deposit such funds weekly in accordance with Department of Agriculture regulations. Requires more frequent deposit of balances of $1,000 or more. States that vendors act as fiduciaries of the Federal Government when receiving food coupon funds. Prohibits the use of such funds by vendors for the benefit of any other than the Federal Government. Requires vendors to report periodically to State and Federal Government agencies the amount of funds deposited. Establishes criminal penalties for the violation of the regulations established in accordance with this Act.
United States · United States Congress · 4 May 1976
Legal Fees Reimbursement Act - Provides that in any legal action initiated by the Government, or in any action instituted by a taxpayer contesting the accuracy of a deficiency or claiming a refund of taxes paid where the taxpayer prevails or substantially prevails, the Government shall be liable for the reimbursement in full of all reasonable litigation expenses incurred by the taxpayer as a consequence of legal defense, under the Internal Revenue Code.