PUBLIC LAW 104-168-^ULY 30, 1996 110 STAT. 1453 TITLE VII—AWARDING OF COSTS AND CERTAIN FEES Sec. 701. United States must establish that its position in proceeding was substantially justified. Sec. 702. Increased limit on attorney fees. Sec. 703. Failure to agree to extension not taken into account. Sec. 704. Award of litigation costs permitted in declaratory judgment proceedings. TITLE VIII—MODIFICATION TO RECOVERY OF CIVIL DAMAGES FOR UNAUTHORIZED COLLECTION ACTIONS Sec. 801. Increase in limit on recovery of civil damages for unauthorized collection actions. Sec. 802. Court discretion to reduce award for litigation costs for failure to exhaust administrative remedies. TITLE IX—MODIFICATIONS TO PENALTY FOR FAILURE TO COLLECT AND PAY OVER TAX Sec. 901. Preliminary notice requirement. Sec. 902. Disclosure of certain information where more than 1 person liable for penalty for failure to collect and pay over tax. Sec. 903. Right of contribution where more than 1 person liable for penalty for failure to collect and pay over tax. Sec. 904. Volunteer bo£u*d members of tax-exempt organizations exempt from penalty for failure to collect and pay over tax. TITLE X—MODIFICATIONS OF RULES RELATING TO SUMMONSES Sec. 1001. Enrolled agents included as third-party recordkeepers. Sec. 1002. Safeguards relating to designated summonses. Sec. 1003. Annual report to Congress concerning designated summonses. TITLE XI—RELIEF FROM RETROACTIVE APPLICATION OF TREASURY DEPARTMENT REGULATIONS Sec. 1101. Relief from retroactive application of Treasury Department regulations. TITLE XII—MISCELLANEOUS PROVISIONS Sec. 1201. Phone number of person providing payee statements required to be shown on such statement. Sec. 1202. Required notice of certain payments. Sec. 1203. Unauthorized enticement of information disclosure. Sec. 1204. Annual reminders to taxpayers with outstanding delinquent accounts. Sec. 1205. 5 -year extension of authority for undercover operations. Sec. 1206. Disclosure of Form 8300 information on cash transactions. Sec. 1207. Disclosure of returns and return information to designee of taxpayer. Sec. 1208. Study of netting of interest on overpayments and liabilities. Sec. 1209. Expenses of detection of underpayments and fraud, etc. Sec. 1210. Use of private delivery services for timely-mailing-as-timely-filing rule. Sec. 1211. Reports on misconduct of IRS employees. TITLE XIII—REVENUE OFFSETS Subtitle A—Application of Failure-to-Pay Penalty to Substitute Returns Sec. 1301. Application of failure-to-pay penalty to substitute returns. Subtitle B—Excise Taxes on Amounts of Private Excess Benefits Sec. 1311. Excise taxes for failure by certain charitable organizations to meet certain qualification requirements. Sec. 1312. Reporting of certain excise taxes and other information. Sec. 1313. Exempt organizations required to provide copy of return. Sec. 1314. Increase in penalties on exempt organizations for failure to file complete and timely annual returns. TITLE I—TAXPAYER ADVOCATE SEC. 101. ESTABLISHMENT OF POSITION OF TAXPAYER ADVOCATE WmnN INTERNAL REVENUE SERVICE. (a) GENERAL RULE.—Section 7802 (relating to Commissioner of Internal Revenue; Assistant Commissioner (Employee Plans and
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