BENAVIDES, Circuit Judge:
The appellant, Patricia Rae Koehler, appeals from the district court's dismissal of her claims against the United States on the grounds that the United States was entitled to sovereign immunity. For the reasons set forth below, we AFFIRM.
Background
In the early 1990s, the Internal Revenue Service ("IRS") determined that Koehler (hereinafter "taxpayer") owed federal income taxes for the years ending December 31, 1988...
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