IRS Independent Office of Appeals Recovering Administrative and Litigation Costs (Part I)
IRS Independent Office of Appeals
Recovering Administrative and Litigation Costs (Part I)
You may be able to recover your reasonable administrative and litigation costs if you are the
prevailing party and if you meet the other requirements. For example, you must exhaust your
administrative remedies within the IRS including participating in the Appeals process, and you
must not unreasonably delay the administrative or court proceedings.
-Administrative costs are costs incurred for administrative proceedings on or after the date
you receive the first letter of proposed deficiency giving you an opportunity for review in
Appeals, the Appeals decision letter, or the notice of deficiency, whichever is earliest.
-Litigation costs are costs incurred for court proceedings.
Next week: Recovering Administrative and Litigation Costs (Part II)
(IRS PUBLICATION 5) (TTT 082724)