| 8.__Prevailing party.__"Prevailing party" means a party in a |
| proceeding to which this chapter applies, other than the |
| United States, the State or the bureau or any creditor of the |
| taxpayer involved, who meets the requirements of section 107 |
| and who has substantially prevailed with respect to the amount |
| in controversy or the most significant issue or set of issues |
| presented. |