Task: Wrong Candidate Generation
Input (English): ie., the presence of an elaborate mechanism for the resolution of claims] are applicable here with respect to the NCBA’s allegations of violations of the fifth amendment due process clause and of various provisions of the Internal Revenue Code. Although there may be no established mechanism for the recovery of damages against federal authorities for unconstitutional conduct, the unavailability of complete relief does not mandate the creation of a Bivens remedy when other “meaningful safeguards or remedies for the rights of persons situated as were the plaintiffs” are available. In this case, the NCBA has recourse to challenge the legality of the penalty assessment under several provisions of the Internal Revenue Code. Accord Dahn v. United States, 127 F.3d 1249, 1254 (10th Cir.1997) (<HOLDING>). The conduct which gives rise to this action 
 Holding statements: (A) holding that comprehensive administrative scheme signals that congress did not intend to permit service members to assert a private cause of action in federal court under the mwpa (B) holding that in light of the comprehensive administrative scheme created by congress to resolve taxrelated disputes individual agents of the irs are also not subject to bivens actions (C) holding that a remedial scheme created by congress even if incapable of addressing all of plaintiffs injuries precluded a bivens action (D) holding that in its review of the irs exercise of discretion the court is limited to a review of the administrative record (E) holding that irs agents did not violate the fourth amendment by conducting surveillance in violation of regulations requiring prior authorization because neither the constitution nor any act of congress requires that official approval be secured before conversations are overheard or recorded by government agents with the consent of one of the eonversants
Output (English): holding that in its review of the irs exercise of discretion the court is limited to a review of the administrative record