Taxpayer Protection and Reimbursement Act

Summary

Taxpayer Protection and Reimbursement Act - Amends the Internal Revenue Code to permit reasonable court costs, including attorneys' fees, to be awarded 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 $25,000 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: (1) establishes that the position of the United States in the civil action was unreasonable; and (2) substantially prevails with respect to the amount in controversy or the most significant issue or set of issues. Disallows costs for certain civil actions involving declaratory judgments.

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1 official file

• Introduced in Senate

  summary · EN · 28 September 1981

  Open at official source

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