NOONAN, Circuit Judge:
Frank R. and Janis K. Lewis, taxpayers, (the Lewises) appeal from the judgment of the district court in their suit against the United States. The Lewises have incurred over $15,000 of legal fees in their successful effort to recover the sum of $1,794.92 that the government finally conceded was due them. The sole issue on this appeal is whether the government was "substantially justified" in its position of refusing to make this payment up to...
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