Court of Appeals for the Eighth Circuit May 5, 1978, 77-1646 (Bryan M. Patzkowski v. United States)

GIBSON, Chief Judge.

This is an appeal by Bryan Patzkowski (taxpayer) from a denial of attorney’s fees requested under the. Civil Rights Attorney’s Fees Awards Act of 1976, Pub.L.No.94-559, § 2, 90 Stat. 2641 (amending 42 U.S.C. § 1988). A penalty in the amount of $28,-675.57 was assessed against taxpayer by the Government, pursuant to 26 U.S.C.