Shwarz

Plaintiffs-Appellants Joseph and Beth Shwarz, and the corporation they own, American Boiler Works, Inc. (ABW), brought suit against Defendants-Appellees the United States, the Internal Revenue Service' (IRS), and two IRS agents, Steve Hadley and A1 Bryant, for unauthorized disclosure of tax return information under 5 U.S.C. § 552a and 26 U.S.C. §§ 6103 and 7431, unauthorized tax collection actions under 26 U.S.C. § 7433 , and violations of Fourth and Fifth Amendment rights under Bivens v. Six Unknown Named Agents of the Federal Bureau of Narcotics, 403 U.S. 388 , 91 S.Ct. 1999 , 29 L.Ed.2d 619 (1971). On Appellees’ motion, the district court dismissed all but the § 552a claim, as to which the court subsequently granted Ap-pellees’ motion for summary judgment. We have jurisdiction over this timely appeal pursuant to 28 U.S.C. § 1291 , and we affirm.

I. BACKGROUND

Joseph and Beth Shwarz are the sole shareholders of ABW, which repairs steam boilers for dry cleaners. Steve Hadley and A1 Bryant are employees of the IRS. Bryant was at all relevant times Hadley’s supervisor.

At some time before September 1994, the IRS assessed a Trust Fund Recovery Penalty of $47,011 against Joseph…