IRS Independent Office of Appeals  Recovering Administrative and Litigation Costs (Part III)

IRS Independent Office of Appeals  
Recovering Administrative and Litigation Costs (Part III)

To qualify as a prevailing party, you must:

-Substantially prevail on the amount in controversy or the most significant issue(s)
presented, or obtain a final judgment that is less than or equal to a “qualified offer” that
the IRS rejected, AND
– Meet the applicable net worth and size requirements.

Net worth and size limitations:
– For individuals, estates, or trusts, net worth cannot exceed $2,000,000.
– Charities and certain cooperatives must not have more than 500 employees
– A partnership, corporation, association, unit of local government, or organization must
have a net worth of $7,000,000 or less and must not have more than 500 employees.
– In TEFRA partnership proceedings, both the partnership and the requesting partner must
meet relevant net worth and size limitations.

Next week: Recovering Administrative and Litigation Costs (Part IV)

(IRS PUBLICATION 5) (TTT 091024)