#assessment attorneyfee irs cpapartners cpapartnersml

[cpapartners]

Lesson From The Tax Court: Taxpayer Who Got $1.6m Assessment Reduced To $170k Not Entitled To Costs (TaxProf Blog) - To get awards of costs and attorneys fees under §7430, a taxpayer must be a “prevailing party.” Taxpayers who jump that hurdle then face a bunch of other requirements, such as a net worth requirement, a very strict administrative exhaustion requirement and, most difficult of all, the requirement that the IRS’s position in the proceeding was not substantially justified