A bill to amend the Internal Revenue Code of 1954 to provide for the awarding of reasonable court costs and certain fees to prevailing parties in civil tax actions, and for other purposes.
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 $20,000 for any one civil action.
Includes within the definition of "attorney's 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.
Other Measure H.R.4961 Forwarded by Subcommittee to Full Committee in Lieu.
Introduced in Senate
Read second time and referred to Senate Committee on Finance.
Committee on Finance requested executive comment from OMB; Treasury Department.
Subcommittee on Oversight of the IRS took the following actions.
Subcommittee on Oversight of the IRS. Hearings held.
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