EDWARD S. SMITH, Senior Circuit Judge:
Debtor Pierce Lamar Hardy appeals the decision of the United States District Court for the Southern District of Georgia denying him relief against the Internal Revenue Service ("IRS") under the permanent injunction provision of 11 U.S.C. § 524(a)(2). The district court dismissed Hardy's action due to lack of jurisdiction after finding that there was no express unequivocal waiver of sovereign
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