Patrick McGrogan v. Commissioner of Internal Reven

OPINION

(May 17, 2013)

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 dismissed Taxpayers’ claims against the IRS for lack of subject matter jurisdiction. McGrogan also filed a claim against the VIBIR that…