MEMORANDUM
JOSEPH H. YOUNG, District Judge.
Plaintiffs Katherine and Samuel Furcron, American citizens who divide their time between Mexico and the United States, have filed this suit against the United States, the Federal Reserve Bank of New York ("FRB"), and Citibank, N.A. ("Citibank"). Plaintiffs allege that they timely tendered to the Internal Revenue Service a $10,000 cashier's check drawn on a Mexican bank in satisfaction of their 1979 tax liability...
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