,,ii  #aagth ,,congress  #b;d ,session  
,s4 #ejad  ,,in ,,the ,,senate ,,of     
,,the ,,united ,,states  ,september #bi1
 #bjbb,mr4 ,marshall 7for himself and   
,mr4 ,braun7 introduced the following   
bill2 which was read twice and referred 
to the ,committee on ,finance  ,a ,,bill
  ,to require the ,internal ,revenue    
,service to pay for costs incurred by   
certain persons in the course of an     
audit4  #a4 ,short title ,this ,act may 
be cited as the ,preventing ,frivolous  
,actions by ,,irs ,agents ,act4  #b4    
,fees and expenses of audits  7a7 ,in   
general ,subchapter ,a of chapter #gh of
 the ,internal ,revenue ,code of #aihf  
is amended by redesignating section     
#gfac as section #gfad and by inserting 
after section #gfab the following new   
section3  #gfac4 ,fees and expenses of  
audits  7a7 ,in general ,in the case of 
an eligible taxpayer1 the taxpayer shall
 be entitled to the payment of any fees 
or other expenses paid or incurred by   
the taxpayer in the course of an audit  

under this subtitle4  7b7 ,timing of    
payment ,the payment under subsection   
7a7 shall be due after the disposition  
of the taxpayer's case1 including       
completion of any judicial proceedings4 
7c7 ,eligible taxpayer ,for purposes of 
this section1 the term eligible taxpayer
 means a taxpayer whose gross income for
 the taxable year in which the audit is 
commenced does not exceed #djj1jjj1 and 
who is not convicted of any crime       
related to the audit described in       
subsection 7a7 or the case described in 
subsection 7b74  4  7b7 ,clerical       
amendment ,the table of sections for    
subchapter ,a of chapter #gh of the     
,internal ,revenue ,code of #aihf is    
amended by adding at the end the        
following3  ,sec4 #gfac4 ,fees and      
expenses of audits4  4  #c4 ,attorney's 
fees1 etc  7a7 ,in general ,chapter #gf 
of the ,internal ,revenue ,code of #aihf
 is amended by adding at the end the    
following new subchapter3  ,f ,fees and 
expenses  ,sec4 #gdie4 ,fees and        

expenses4  #gdie4 ,fees and expenses ,in
 the case of any civil or criminal      
proceeding brought by or at the request 
of the ,secretary in which the taxpayer 
prevails in court1 the taxpayer shall be
 entitled to the payment of attorney's  
fees1 court costs1 and other expenses   
related to the taxpayer's defense in    
such proceeding4  4  7b7 ,clerical      
amendment ,the table of subchapters for 
chapter #gf of the ,internal ,revenue   
,code of #aihf is amended by adding at  
the end the following3  ,,subchapter    
,f--,fees and expenses  4