HATCHETT, Circuit Judge:
Taxpayers sought injunctive and mandamus relief based upon taxpayers' interpretation of 26 C.F.R. § 601.107(b)(2) as imposing upon the Internal Revenue Service a mandatory obligation to disclose requested information in a criminal investigation. The district court dismissed for lack of jurisdiction. Because we interpret the disclosure aspects of the regulation to be discretionary and find no basis for jurisdiction, we affirm.
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