Fairplay for Taxpayers Act of 1992

[AI summary unavailable — showing source text] Fairplay for Taxpayers Act of 1992 - Amends the Federal Rules of Evidence to declare that the communications between a lawyer, an accountant, or an enrolled agent with respect to the preparation of a tax return for a client and the client shall be privileged in the U.S. courts. Amends the Internal Revenue Code to increase the interest rate for overpayment of tax from two percent to three percent (making such rate equal to the interest rate for underpayment of tax). Provides that if a taxpayer pays the full amount of taxes, interest, and penalties owed within 45 days (currently, ten days) from the date of notice and demand, then no interest liability will be imposed. Requires any final, temporary, or proposed tax regulation or ruling to be applied prospectively from the date of publication in the Federal Register. Provides that such prospective-only treatment may be superseded only by congressional action. Replaces the "substantially-prevailed" test for determining whether a taxpayer may recover costs and fees incurred as part of an administrative or court proceeding with a "prevailed-to-some-extent" test. Allows the taxpayer to recover the same percentage of costs incurred as the p…