GODBOLD, Chief Judge:
Plaintiffs are citizens of the United States who live in Panama and work for and receive a salary from the Panama Canal Commission (PCC). Plaintiffs brought these suits to enjoin the Internal Revenue Service (IRS) from placing tax liens on their property and from seizing their assets, and to require the IRS to return monies already collected and to honor the exemption from tax allegedly granted under the Panama Canal Treaty of 1977.
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