The Supreme Court has granted certiorari in EC Term of Years Trust v. United States, No. 05-1541: May an innocent third party whose property is confiscated by the IRS to satisfy another person’s tax liability and whose wrongful levy action under 26 U.S.C. § 7426 is time-barred instead use a different provision in the tax code, 28 U.S.C. § 1346, to seek a refund? (Hat Tip: Adam Steinman.)



