DENNIS JACOBS, Chief Judge:
Debtor Paul S. Hudson, having successfully challenged a claim lodged against him in the bankruptcy court by the Internal Revenue Service ("IRS"), sought attorney's fees pursuant to 26 U.S.C. § 7430 of the Internal Revenue Code ("IRC"), which permits the prevailing party to recover litigation costs, including attorney's fees, in any proceeding brought by the United States in connection with the collection of interest on past due taxes...
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