Railway Labor, 858 F.2d at 942-43); accord Krashna, 895 F.2d at 114. Arguing that the first requirement is met here, Legg Mason contends that the civil enforcement provision found in 26 U.S.C. § 7426 vindicates the same interest that the plaintiffs seek to vindicate in their state-law claims—their interest in getting back their property. But section 7426 creates a cause of action against the federal government only, not against a third party who surrenders levied property. Because the plaintiffs in this case have chosen to sue the surrendering third party rather than the government, arguably section 7426 does not vindicate the same interest as does plaintiffs’ state-law claims. Cf. Avco Corp. v. Aero Lodge No. 735, 390 U.S. 557, 560-61, 88 S.Ct. 1235, 1237-38, 20 L.Ed.2d 126 (1968) (<HOLDING>); Railway Labor, 858 F.2d at 942 (holding that
recognizing that section 76872 is substantive law even though the state statute was preempted by federal civil rights law holding that statelaw fraudonthefda claim  was preempted by federal law based on uniquely federal nature of regulated relationship recognizing that every theory of relief must raise federal issue for claim to arise under federal law holding a claim under a maryland antisubrogation statute to be completely preempted holding that plaintiffs statelaw claim was completely preempted under federal statute even though relief soughtan injunctionwas not available under the federal statute