GOLDBERG, Circuit Judge:
Louis and Laura Capozzoli brought this suit under the Federal Tort Claims Act, 28 U.S.C. § 2671 et seq. ("FTCA"), for damages based on the allegedly tortious conduct of an agent of the Internal Revenue Service ("IRS"). The District Court dismissed the action on the grounds that it was barred by 28 U.S.C. § 2680(c), an exception to the FTCA which retains the government's sovereign immunity for "[a]ny claims arising in respect...
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