AWARDING OF ADMINISTRATIVE COSTS.

SEC. 1285. AWARDING OF ADMINISTRATIVE COSTS. (a) Right to Appeal Tax Court Decision.—Subsection (f) of section 7430 (relating to right of appeal) is amended by adding at the end the following new paragraph: “(3) Appeal of tax court decision.—An order of the Tax Court disposing of a petition under paragraph (2) shall be reviewable in the same manner as a decision of the Tax Court, but only with respect to the matters determined in such order.”. (b) Period for Applying to IRS for Costs.—Subsection (b) of section 7430 (relating to limitations) is amended by adding at the end the following new paragraph: “(5) Period for applying to irs for administrative costs.—An award may be made under subsection (a) by the Internal Revenue Service for reasonable administrative costs only if the prevailing party files an application with the Internal Revenue Service for such costs before the 91st day after the date on which the final decision of the Internal Revenue Service as to the determination of the tax, interest, or penalty is mailed to such party.”. (c) Period for Petitioning of Tax Court for Review of Denial of Costs.—Paragraph (2) of section 7430(f) (relating to right of appeal) is amended— (1) by striking “appeal to” and inserting “the filing of a petition for review with”, and (2) by adding at the end the following new sentence: “If the Secretary sends by certified or registered mail a notice of such decision to the petitioner, no proceeding in the Tax Court may be initiated under this paragraph unless such petition is filed before the 91st day after the date of such mailing.”.111 STAT. 1039 (d) Effective Date.—The amendments made by this section shall apply to civil actions or proceedings commenced after the date of the enactment of this Act.