CANBY, Circuit Judge:
Erma Stites appeals the district court's denial of her request for attorney's fees and her motion for reconsideration. We dismiss this appeal for lack of jurisdiction.
BACKGROUND
Erma Stites brought an action in the district court pursuant to 26 U.S.C. § 7429(b), seeking to abate a jeopardy assessment made against her by the Internal Revenue Service ("IRS")
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