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Tax Lawyer, Vol. 61, No. 1 NOTES 339NOTEA Second Bite? The Availability of Section 1346(a)(1) as an Alternative Remedy to Section 7426(a)(1) in EC Term of Years Trust v. United States If the Service levies upon your property to satisfy the tax liabilities of another, what possible remedies do you have?1 You may certainly bring a wrongful levy action under section 7426(a)(1).2 Unfortunately, however, the statute of limitations for bringing such an action is generally only nine months.3 If you miss...