WATERMAN, Circuit Judge:
This action was commenced in the United States District Court for the Southern District of New York by John R. Seybert and Victor Soto, two members of the Offshore Division of the International Organization of Masters, Mates & Pilots of America, AFL-CIO ("International" or "IOMM&P"), seeking the return of monies paid to the IOMM&P during the period 1974 through 1977 by virtue of an allegedly unauthorized per capita tax levied on...
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