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Plaintiff-appellant, Beresford Williams, appeals from a judgment entered on March 1, 1991 in the United States District Court for the Eastern District of New York (Nickerson, J.) dismissing an action commenced against defendant-appellee, the United States. In the suit, Williams sought to recover $30,563, plus interest and costs, which he alleged had been collected wrongfully by the Internal Revenue Service ("IRS") pursuant to a notice of levy issued to the New York City Police Department ("police department"). The district court found that the action was untimely under 26 U.S.C. § 6532(c) (1988). Williams contends that the district court applied the wrong statute of limitations and that, because he filed his complaint within ten months of the IRS's denial of his request for the levied money, the action is timely. We reject this argument and affirm the judgment of the district court.


947 F.2d 37 (1991)

Beresford WILLIAMS, Plaintiff-Appellant,


UNITED STATES of America, Defendant-Appellee.

No. 1756, Docket 91-6065. United States Court of Appeals, Second Circuit.

Argued August 14, 1991.

Decided October 10, 1991.

New York Law School location: File #1284, Box #128