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UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA 10 MARY A. NELSON ROGERS, No. 2:19-cv-01564-TLN-CKD PS Plaintiff, v. FINDINGS AND RECOMMENDATIONS THE UNITED STATES OF AMERICA, (ECF No. 64) Defendant. 16 Presently before the court is defendant’s motion to dismiss plaintiff’s Fifth Amended Complaint. (ECF No. 64.) Plaintiff has filed an opposition. (ECF No. 65.) The court is deciding the motion without a hearing pursuant to Local Rule 230(g). For the reasons that follow, the undersigned recommends granting defendant’s motion and dismissing plaintiff’s complaint without leave to amend. BACKGROUND1 Plaintiff alleges that the present action “arises out of the Internal Revenue Service[’s] . . . wrongful acts and omissions concerning [plaintiff]” in violation of multiple sections of the United States Code. (ECF No. 62 at 2.) More specifically, plaintiff alleges that IRS agents “repeatedly 26 1 Unless otherwise indicated the undersigned refers to the operative Fifth…