Nor is there any merit in Ms. Hook’s related argument that the court erred in denying discovery. The district court pointed to the magistrate judge’s findings that the parties had already submitted a large volume of exhibits and that "Plaintiffs failed to identify any specific discovery necessary to the determination of the merits of Defendant’s jurisdictional arguments." Aplt. App. at 458. On appeal, Ms. Hook points to discovery requests she would have submitted if allowed to do so, but the requests broadly sought all documents and electronically stored information that the government would rely on to defend the action. She appears to argue that the government should have been required to produce all the documentation underlying the summaries attached to the Tibbs declaration. But Ms. Hook offers no specific challenge to the accuracy of the summaries other than to point to competing statements in the amended complaint, which, as we will soon discuss, were insufficient to forestall dismissal. In sum, we see no abuse of discretion in the district court’s refusal to grant discovery before ruling on the motion to dismiss the amended complaint. See Garcia v. Tyson Foods, Inc., 770 F.3d 1300, 1309 (10th Cir. 2014) (“We review the district court’s discovery decisions for abuse of discretion and will reverse only if [the complaining party] makes a clear showing that the denial of discovery resulted in actual and substantial prejudice.” (footnote and internal quotation marks omitted)).
C. Claims under 26 U.S.C. §§ 6512, 6343
Ms. Hook takes issue with the district court’s conclusion that 26 U.S.C. § 6512(a) precluded plaintiffs from contesting the Tax Court’s determination of their
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