Taxpayer Protection and Reimbursement Act

Summary

Taxpayer Protection and Reimbursement Act - Title I: Amendments to Internal Revenue Code of 1954 - Amends the Internal Revenue Code to award reasonable court costs, including attorneys' fees, to the prevailing party (other than the United States or a creditor of the prevailing party) in any civil action in any court of the United States for the determination, collection, or refund of any tax, interest, or penalty imposed under the Internal Revenue Code. Limits the amount of such award to $20,000 for any one civil action. Includes within the definition of "attorneys' fees" amounts paid to an individual who is not an attorney, but who is authorized to practice before the Tax Court. Defines "prevailing party" as a party who recovers all, or all but an insignificant portion of the amount in controversy in a civil tax proceding, or whose position is sustained as to all, or all but an insignificant portion, of the issues involved, and who establishes that the position of the United States in the civil action was unreasonable. Disallows costs and attorneys' fees for certain civil actions involving declaratory judgments. Title II: Amendments to Title 28 - Incorporates into title 28 (Judiciary and Judicial Procedure) of the United States Code the amendments set forth in title I of this Act.

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1 official file

• Introduced in Senate

  summary · EN · 27 June 1979

  Open at official source

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