ORDER
The memorandum disposition filed February 4, 1988, is redesignated as a Per Curiam Opinion per the attached Opinion.
OPINION
PER CURIAM:
The United States of America appeals the district court's judgment awarding Lloyd and Constance Latch (the "Latches") $12,137.25 in attorney's fees and costs pursuant to 26 U.S.C. § 7430 after the parties settled the underlying dispute concerning the...
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