are valid, as they “are essentially the same as used by the banking industry ... there certainly cannot be different laws for the ba ); see also Donahue v. United States, 33 Fed.Cl. 600, 604 (1995) (same)). Plaintiffs had an opportunity to dispute the validity of the notice of deficiency 9 Second Amended Complaint that certain Government officials acted unlawfully and committed fraud in violation of Plaintiffs’ due process rights is a tort claim over which the court does not have jurisdiction. Id. Moreover, Section 7433(a) of the Internal Revenue Code provides that a claim for money damages for unauthorized collections by the IRS must be brought exclusively “in a district court of the United States.” 26 U.S.C. § 7433(a); see also Brown v. United States, 105 F.3d 621, 624 (Fed.Cir.1997) (<HOLDING>); Thorndike v. United States, 72 Fed.Cl. 580,
holding that this court does not have jurisdiction over plaintiffs claims because the court may review neither criminal matters nor the decisions of district courts holding that this court does not have jurisdiction over tax claims for declaratory or equitable relief holding that the united states court of federal claims does not have jurisdiction to enter declaratory judgment that taxpayers were not liable for any type of federal income tax or to issue injunction permanently removing the tax liens on property and levies on wages holding this court generally lacks jurisdiction over the sec 6651a2 addition to tax for failure to pay tax holding that direct access suit concerning propriety of default termination is request for declaratory relief over which claims court has no jurisdiction