MEMORANDUM-DECISION AND ORDER
BARTELS, Senior District Judge.
This is an action by a party other than the taxpayer, under 26 U.S.C. § 7426, to recover monies levied upon by the Internal Revenue Service. Defendant United States of America moves to dismiss for lack of subject matter jurisdiction on the ground that there has been no waiver of the United States' sovereign immunity since the plaintiff failed to file the action within the applicable statute...
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