Awards of Attorney Fees In Tax Cases
Internal Revenue Manual Part 4. Examining Process · 2026-10-03 edition · updated 2026-10-04 · United States
The purpose of this section is to:
Advise examiners of the provisions of IRC 7430.
Emphasize the principles they must uphold when performing their duties.
The Equal Access to Justice Act, P.L. 96-481, 94 Stat. 2328, amended Title 28, the Judicial Code, to award costs, attorney fees and other expenses to "prevailing parties" in any civil tax action in the U.S. District Courts or the Court of Claims when:
The Government has acted in "bad faith."
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