APPLICATION OF NET WORTH REQUIREMENT FOR AWARDS OF LITIGATION COSTS.

SEC. 1453. APPLICATION OF NET WORTH REQUIREMENT FOR AWARDS OF LITIGATION COSTS. (a) In General.—Paragraph (4) of section 7430(c) (defining prevailing party) is amended by adding at the end thereof the following new subparagraph: “(D) Special rules for applying net worth requirement.—In applying the requirements of section 2412(d)(2)(B) of title 28, United States Code, for purposes of subparagraph (A)(iii) of this paragraph— “(i) the net worth limitation in clause (i) of such section shall apply to— “(I) an estate but shall be determined as of the date of the decedent’s death, and “(II) a trust but shall be determined as of the last day of the taxable year involved in the proceeding, and “(ii) individuals filing a joint return shall be treated as separate individuals for purposes of clause (i) of such section.”. (b) Effective Date.—The amendment made by this section shall apply to proceedings commenced after the date of the enactment of this Act.