Today, Treasury and the IRS issued final regulations (TD 9756) under section 7430 relating to awards of administrative costs and attorneys’ fees.  Section 7430 generally authorizes a court to award administrative and litigation costs, including attorneys’ fees, to a prevailing party in an administrative or court proceeding brought by or against the US in connection with the determination, collection, or refund of any tax, interest, or penalty.  The final regulations conform the regulations to amendments made in the Taxpayer Relief Act of 1997 and the IRS Restructuring and Reform Act of 1998.  Among other changes, the final regulations specify which limitations with respect to net worth and size apply when a taxpayer is an owner of an unincorporated business, and clarify the net worth and size limitations in cases involving partnerships subject to the unified audit and litigation procedures of sections 6221 through 6234 (the TEFRA partnership procedures).  (Section 7430 imposes net worth and size limitations on who can recover costs.)  The final regulations are effective March 1.