administrative proceedingmeans any procedure or other action before the Internal Revenue Service.
chief judgemeans the chief judge of the Tax Court.
court proceedingmeans any civil action brought in a court of the United States (including the Tax Court and the United States Court of Federal Claims).
dependent childmeans an unmarried child, including a dependent stepchild or an adopted child, who is under the age of 18 years or who because of physical or mental disability is incapable of self-support.
employment taxmeans any tax imposed by subtitle C.
foreign trust or estateincludes an estate or trust, any fiduciary of which is a foreign corporation or nonresident alien individual;
information returnmeans any statement described in section 6724(d)(1)(A).
judgemeans the chief judge or a judge of the Tax Court;
prevailing partymeans any party in any proceeding to which subsection (a) applies (other than the United States or any creditor of the taxpayer involved)—
qualified offermeans a written offer which—
reasonable administrative costsmeans— Such term shall only include costs incurred on or after whichever of the following is the earliest: (i) the date of the receipt by the taxpayer of the notice of the decision of the Internal Revenue Service Independent Office of Appeals;
reasonable litigation costsincludes— In the case of any calendar year beginning after 1996, the dollar amount referred to in clause (iii) shall be increased by an amount equal to such dollar amount multiplied by the cost-of-living adjustment determined under section 1(f)(3) for such calendar year, by substituting “calendar year 1995” for “calendar year 2016” in subparagraph (A)(ii) thereof.
special trial judgemeans a judicial officer appointed pursuant to section 7443A, including any individual receiving an annuity under chapter 83 or 84 of title 5, United States Code.
specified conductmeans any action, or failure to take action, which is—
surviving spousemeans a surviving spouse of an individual, who either (A) shall have been married to such individual for at least 2 years immediately preceding his death or (B) is a parent of issue by such marriage, and who has not remarried.
survivors annuity fundmeans the Tax Court judges survivors annuity fund established by this section.
Tax Courtmeans the United States Tax Court.
unfunded liabilitymeans the amount estimated by the Secretary to be equal to the excess (as of the close of the fiscal year involved) of—