[19990309]RS20108_纳税人权利法案3：1998年税法第3部分：因国税局滥用职权而产生的律师费和损害赔偿.pdf

Congressional Research Service The Library of CongressCRS Report for CongressReceived through the CRS WebOrder Code RS20108March 9, 1999Taxpayer Bill of Rights 3: 1998 Tax Law Part 3:Attorneys Fees and Damages for IRS AbusesMarie B. MorrisLegislative AttorneyAmerican Law DivisionSummaryThis is one of a series of reports designed to analyze taxpayer protection and rightsprovisions made by the Taxpayer Bill of Rights 3, enacted as Title III of the IRSRestructuring and Reform Act of 1998, P.L. 105-206. This report discusses theprovisions expanding a courts authority to award attorneys fees and costs in certaincases and permitting a taxpayer to collect damages for negligent collection actions byIRS agents. Specific statutory changes include an increase in the previous statutory capon attorneys fees, the provision of fees to accountants and enrolled agents, and theauthority to pay fees for successful pro bono representation. These provisions are foundin sections 3101 and 3102 of the statute and in IRC 7430, 7433, and 7426.The Taxpayer Bill of Rights 3, title III of P.L. 105-206, contains a number ofprovisions designed to strengthen taxpayer rights in dealings with the Internal RevenueSe