102 STAT. 3746	PUBLIC LAW 100-647-NOV. 10, 1988
"(i) the date of the receipt by the taxpayer of the
notice of the decision of the Internal Revenue Service
Office of Appeals, or
"(ii) the date of the notice of deficiency,
"(d) special rules for payment of costs.—
"(1)   reasonable   administrative   costs.—An   award   for
reasonable administrative costs shall be payable out of funds
appropriated under section 1304 of title 31, United States Code.
"(2) reasonable litigation costs.—An award for reasonable
litigation costs shall be payable in the case of the Tax Court in
the same manner as such an award by a district court.
"(e) multiple actions.—For purposes of this section, in the case
of—
"(1) multiple actions which could have been joined or consoli-
dated, or
"(2) a case or cases involving a return or returns of the same
taxpayer (including joint returns of married individuals) which
could have been joined in a single court proceeding in the same
court,
such actions or cases shall be treated as 1 court proceeding regard-
less of whether such joinder or consolidation actually occurs, unless
the court in which such action is brought determines, in its discre-
tion, that it would be inappropriate to treat such actions or cases as
joined or consolidated.
"(0 right of appeal.—
"(1) court proceedings.—An order granting or denying (in
whole or in part) an award for reasonable litigation or adminis-
trative costs under subsection (a) in a court proceeding, may be
incorporated as a part of the decision or judgment in the court
proceeding and shall be subject to appeal in the same manner as
the decision or judgment.
"(2) administrative proceedings.—A decision granting or
denying (in whole or in part) an award for reasonable adminis-
trative costs under subsection (a) by the Internal Revenue
Service shall be subject to appeal to the Tax Court under rules
similar to the rules under section 7463 (without regard to the
amount in dispute)/'
(b)	conforming amendment.—Section 504 of title 5, United
States Code, is amended by adding at the end thereof the following
new subsection:
"(f) No award may be made under this section for costs, fees, or
other expenses which may be awarded under section 7430 of the
Internal Revenue Code of 1986."
(c)	clerical amendment.—The table of sections for subchapter B
of chapter 76 of the 1986 Code is amended by striking out "court" in
the item relating to section 7430.
26 use 7430	(d) effective date.—The amendments made by this section shall
^note	apply to proceedings commencing after the date of the enactment of
this Act
SEC. 6240. CIVIL CAUSE OF ACTION FOR DAMAGES SUSTAINED DUE TO
FAILURE TO RELEASE LIEN.
(a) in general.—Subchapter B of chapter 76 of the 1986 Code
(relating to proceedings by taxpayers and third parties) is amended
by redesignating section 7432 as section 7433 and by inserting after
section 7431 the following new section: