To the extent Mr. Roberts made claims which would only be cognizable under the FTCA, he has not demonstrated that he presented his tort claims in the first instance to the IRS as required by 28 U.S.C. § 2675(a). He has therefore failed to exhaust his remedies under the statute, thus depriving the federal court of jurisdiction over these claims. Kendall v. Watkins, 998 F.2d 848, 852 (10th Cir.1993). Freedom of Information Act As with his tort claims, Mr. Roberts has failed to demonstrate that he has exhausted his remedies under the Freedom of Information Act (FOIA) because he did not allege that he complied with the notice requirements of 26 C.F.R. § 601.702(c)(4)(i)(C). The district court thus properly dismissed the FOIA claim. See Taylor v. Appleton, 30 F.3d 1365, 1367 (11th Cir.1994) (<HOLDING>). Refusal to Grant Default Judgment Mr. Roberts
holding that federal prisoners need not exhaust their administrative remedies before filing suit in federal court holding that courts have consistently required exhaustion of administrative remedies under foia holding that the foia clearly requires a party to exhaust all administrative remedies before seeking redress in the federal courts and collecting cases recognizing the general rule that parties must exhaust prescribed administrative remedies before seeking relief from federal courts  holding that an alien must exhaust administrative remedies before seeking habeas relief from detention