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Get Notice 98-55 - Awards Of Costs And Certain Fees In Tax Litigation. Awards Of Costs And Certain Fees

N Notice 98 55 Section 3101(e) of the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. No. 105 206, amended 7430 of the Internal Revenue Code to add a qualified offer rule that treats certain taxpayers as prevailing parties when the United States has rejected their offer to settle their tax controversy. Treatment as a prevailing party is a necessary element for a taxpayer to receive an award of reasonable administrative and litigation costs in connection with a.

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