Page:Hook v. United States.pdf/12

 § 6512(a)(2) purposes (internal quotation marks omitted)). Because Ms. Hook does not explain how the amended complaint accounts for interest and penalties (and it is not obvious from the amended complaint, which lists only the original tax liabilities as determined by the Tax Court), we reject the notion that there was a material jurisdictional-fact issue in dispute with regard to the refund claim. Further, the fact that plaintiffs failed to show that the tax liabilities were paid forecloses Ms. Hook’s challenge to the district court dismissal of the claim for release of levies and return of levied property. The district court correctly held that plaintiffs failed to meet the relevant requirement for a successful release-of-levy claim—satisfaction of the underlying liability. See 26 U.S.C. § 6343(a)(1)(A) (stating that the government shall release a levy “if. . . the liability for which such levy was made is satisfied or becomes unenforceable by reason of lapse of time”). 12