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FLORIDA SUNCOAST VILLAS, INC. v. UNITED STATES

No. 85-3310 Non-Argument Calendar.

776 F.2d 974 (1985)

FLORIDA SUNCOAST VILLAS, INC., Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Eleventh Circuit.

November 21, 1985.

Attorney(s) appearing for the Case

Glenn L. Archer, Jr., Michael L. Paup, William S. Estabrook, Steven I. Frahm, Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellant.

Mark R. Lewis, St. Petersburg, Fla., for plaintiff-appellee.

Before TJOFLAT, VANCE and KRAVITCH, Circuit Judges.

PER CURIAM:

I. BACKGROUND

Florida Suncoast Villas ("Suncoast") filed a complaint against the United States alleging that it had a superior lien on the corporate accounts receivable levied on by the Internal Revenue Service. The district court ruled in favor of Suncoast and entered judgment. Suncoast then filed an application for an award of attorney's fees and costs under the Equal Access to Justice Act ("EAJA"...

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