Rule 230. General

(a) Applicability: The Rules of this Title XXIII set forth the special provisions which apply to claims for reasonable litigation and administrative costs authorized by Code Section 7430. Except as otherwise provided in this Title, the other Rules of Practice and Procedure of the Court, to the extent pertinent, are applicable to such claims for reasonable litigation and administrative costs. See Title XXVI for Rules relating to separate actions for administrative costs, authorized by Code Section 7430(f)(2).

(b) Definitions: As used in the Rules in this Title-

(1) "Reasonable litigation costs" include the items described in Code Section 7430(c)(1).

(2) A "deficiency action" is an action to redetermine a deficiency determined by the Commissioner in income, gift, or estate tax or in the taxes under Code Chapter 41, 42, 43, or 44 (relating to the excise taxes on certain organizations and persons dealing with them), or in the tax under Code Chapter 45 (relating to the windfall profit tax), or in any other taxes which are the subject of a notice of deficiency by the Commissioner.

(3) A "liability action" is an action to redetermine fiduciary or transferee liability determined by the Commissioner.

(4) A "partnership action" is an action for readjustment of partnership items under Code Section 6226 or adjustment of partnership items under Code Section 6228.

(5) A "revocation action" is an action for declaratory judgment involving the revocation of a determination that an organization is described in Code Section 501(c)(3).

(6) In the case of a partnership action, the term "party" includes the partner who filed the petition, the tax matters partner, and each person who satisfies the requirements of Code Section 6226(c) and (d) or 6228(a)(4). See Rule 247(a).

(7) "Attorney's fees" include fees paid or incurred for the services of an individual (whether or not an attorney) who is authorized to practice before the Court or before the Internal Revenue Service. For the procedure for admission to practice before the Court, see Rule 200.

(8) "Reasonable administrative costs" means the items described in Code Section 7430(c)(2).

(9) "Administrative proceeding" means any procedure or other action before the Internal Revenue Service.

(10) "Court proceeding" means the deficiency, liability, partnership, or revocation action brought in this Court and in which the claim for reasonable litigation costs or reasonable administrative costs is made.