{"abstract":"This document contains final regulations relating to the qualified offer rule, including the requirements that an offer must satisfy to be treated as a qualified offer under section 7430(g) and the requirements that a taxpayer must satisfy to qualify as a prevailing party by reason of having made a qualified offer. The regulations implement certain changes made by section 3101(e) of the Internal Revenue Service Restructuring and Reform Act of 1998. The final regulations affect taxpayers seeking attorney's fees and costs.","action":"Final regulations and removal of temporary regulations.","agencies":[{"raw_name":"DEPARTMENT OF THE TREASURY","name":"Treasury Department","id":497,"url":"https://www.federalregister.gov/agencies/treasury-department","json_url":"https://www.federalregister.gov/api/v1/agencies/497","parent_id":null,"slug":"treasury-department"},{"raw_name":"Internal Revenue Service","name":"Internal Revenue Service","id":254,"url":"https://www.federalregister.gov/agencies/internal-revenue-service","json_url":"https://www.federalregister.gov/api/v1/agencies/254","parent_id":497,"slug":"internal-revenue-service"}],"body_html_url":"https://www.federalregister.gov/documents/full_text/html/2003/12/29/03-31822.html","cfr_references":[{"chapter":null,"citation_url":null,"part":301,"title":26}],"citation":"68 FR 74848","comment_url":null,"comments_close_on":null,"correction_of":null,"corrections":[],"dates":"Effective Date: These regulations are effective December 24, 2003.","disposition_notes":null,"docket_ids":["TD 9106"],"dockets":[],"document_number":"03-31822","effective_on":"2003-12-24","end_page":74855,"executive_order_notes":null,"executive_order_number":null,"full_text_xml_url":"https://www.federalregister.gov/documents/full_text/xml/2003/12/29/03-31822.xml","html_url":"https://www.federalregister.gov/documents/2003/12/29/03-31822/awards-of-attorneys-fees-and-other-costs-based-upon-qualified-offers","images":{},"images_metadata":{},"json_url":"https://www.federalregister.gov/api/v1/documents/03-31822?publication_date=2003-12-29","mods_url":"https://www.govinfo.gov/metadata/granule/FR-2003-12-29/03-31822/mods.xml","not_received_for_publication":null,"page_length":8,"page_views":{"count":41,"last_updated":"2026-10-23 06:15:04 -0400"},"pdf_url":"https://www.govinfo.gov/content/pkg/FR-2003-12-29/pdf/03-31822.pdf","presidential_document_number":null,"proclamation_number":null,"public_inspection_pdf_url":null,"publication_date":"2003-12-29","raw_text_url":"https://www.federalregister.gov/documents/full_text/text/2003/12/29/03-31822.txt","regulation_id_number_info":{"1545-AW99":{"issue":"200304","html_url":"https://www.federalregister.gov/regulations/1545-AW99/qualified-offers","title":"Qualified Offers","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=200304&RIN=1545-AW99&operation=OPERATION_EXPORT_XML","priority_category":"Substantive, Nonsignificant"}},"regulation_id_numbers":["1545-AW99"],"regulations_dot_gov_info":{},"regulations_dot_gov_url":null,"significant":false,"signing_date":null,"start_page":74848,"subtype":null,"title":"Awards of Attorney's Fees and Other Costs Based Upon Qualified Offers","toc_doc":"Attorney's fees and other costs based upon qualified offers; awards","toc_subject":"Procedure and administration:","topics":["Employment taxes","Estate taxes","Excise taxes","Gift taxes","Income taxes","Penalties","Reporting and recordkeeping requirements"],"type":"Rule","volume":68}