In conjunction with the final regulations described above, the IRS simultaneously released Revenue Procedure 2016-17.  This revenue procedure provides guidance on the recovery of administrative and litigation costs in connection with the determination, collection, or refund of any tax, interest, or penalty by individuals who provide pro bono representation to taxpayers.  In particular, Revenue Procedure 2016-17 provides that pro bono attorneys who do not charge an hourly rate will receive the statutory rate for their services unless they establish that a special factor, as described in section 7430(c)(1)(B)(iii), applies to justify a higher hourly rate.  This revenue procedure is effective for all motions for costs under section 7430 filed on or after February 29.