MANION, Circuit Judge.
The plaintiff, Amwest Surety Insurance Company ("Amwest"), filed an action against the United States for wrongful tax levy pursuant to 26 U.S.C. § 7426(a)(1). The district court dismissed Amwest's complaint for lack of subject matter jurisdiction because Amwest had failed to bring its action within nine months from the date of the levy as required by 26 U.S.C. § 6532(c)(1). The district court also rejected Amwest's contention that...
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