NEW REGS ON RECOVERY OF LITIGATION COSTS.

• Position: Tax regulations - Brief Article

IRS temporary regulations explain when making a qualified offer will result in the taxpayer being a prevailing party for purposes of a recovery of 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 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...