MEMORANDUM OPINION
WALTON, District Judge.
The plaintiffs, Steven J. Lindsey and Patricia L. Lindsey, bring this action alleging that the United States Internal Revenue Service ("IRS") "recklessly, intentionally or by reason of negligence[,] disregarded and continue to disregard provisions of [the Internal Revenue Code (`IRC'),] Title 26 of the United States Code[,] and the regulations promulgated thereunder." Complaint ("Compl.") ¶ 1. In response...
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