are litigation costs — costs which usually would not have been incurred but for the dispute to which they are attached. In contrast, the costs which faced the district court here were the costs of maintaining the property sought to be forfeited — costs which, in the absence of seizure, might still have been incurred by the claimant. Depending on the equities of the case, some courts have taxed the costs of maintaining seized goods against the government. See, e.g., United States v. One 1965 Chevrolet Impala Convertible, 475 F.2d 882 (6th Cir.1973) (forcing government to bear the cost of depreciation); United States v. One 1969 Plymouth Two-Door Hardtop, 360 F.Supp. 488 (M.D.Ala. 1973) (requiring government to absorb costs of seizure, advertising, and storage). In some insta 1974) (<HOLDING>). Because determining when a forfeiture
holding that because of its civil nature section 881 does not require the government to prove beyond a reasonable doubt that a criminal violation has occurred holding that me const art 1  5 does not require the state to prove probable cause for a search beyond a reasonable doubt holding that the state must prove juvenile delinquency beyond a reasonable doubt holding that because of its civil nature section 881 is not subject to the ex post facto clause holding that the nature and occasion of prior offenses are facts inherent in the convictions which government is not required to allege in the indictment or prove beyond a reasonable doubt