To bring suit against the Internal Revenue Service [hereinafter "Service"] a taxpayer must first cite an act of Congress which waives the Service's protection from lawsuits under the doctrine of sovereign immunity. 28 U.S.C. § 1346(a)(1) permits an individual to bring an action in the district courts for recovery of taxes alleged to have been wrongfully collected by the federal government. The scope of this section, unfortunately, is in dispute as to who has standing to challenge the collection activities of the Internal Revenue Service. As a general rule, citizens cannot challenge the tax liabilities of a third party There are exceptions to this general rule, however.

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