OPINION
ROTH, Circuit Judge:
I. Introduction
In this consolidated appeal, appellants, Barry Cooper, Sandra Cooper, Emmit McHenry, George Huff, and Patrick McGrogan (collectively Taxpayers), filed suits in the District Court of the Virgin Islands seeking redeterminations of their tax liability from the Internal Revenue Service (IRS) and tax refunds from the Virgin Islands Bureau of Internal Revenue (VIBIR). In separate proceedings, the courts below...
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