FARRIS, Circuit Judge:
Berniece Awmiller appeals from the district court's denial of her request for attorney's fees under 26 U.S.C. § 7430. We have jurisdiction over the timely appeal pursuant to 26 U.S.C. § 7430(e) and 28 U.S.C. § 1291. We affirm.
The sole issue is whether the position of the United States in Awmiller's tax refund suit was "substantially justified." 26 U.S.C. § 7430(c)(4)(A)(i). The phrase "substantially justified" means...
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