moving such subparagraphs 2 ems to the right, (2) by striking In any action and inserting the following: (1) In general In any action , and (3) by adding at the end the following new paragraph: (2) Punitive damages for willful and reckless actions In any action brought under subsection (a) or petition filed under subsection (e) in which the defendant is found to be liable and to have acted recklessly or intentionally, the court may award the plaintiff punitive damages. . (c) Period for bringing action Paragraph (3) of section 7433(d) is amended by striking the date the right of action accrues and inserting the later of the date of on which administrative remedies available within the Internal Revenue Service have been exhausted or the date on which the taxpayer reasonably could have discovered that the actions of the officer or employee were done in disregard of a provision of this title or any regulation promulgated under this title . (d) Effective date The amendments made by this section shall apply in the case of proceedings commenced after the date of the enactment of this Act. 202. Extension of time limit for contesting IRS levy (a) Extension of Time for Return of Property Subject to Levy Subsection (b) of section 6343 is amended by striking 9 months and inserting 2 years . (b) Period of Limitation on Suits Subsection (c) of section 6532 is amended— (1) by striking 9 months in paragraph (1) and inserting 2 years , and (2) by striking 9-month in paragraph (2) and inserting 2-year . (c) Effective Date The amendments made by this section shall apply to— (1) levies made after the date of the enactment of this Act, and (2) levies made on or before such date if the 9-month period has not expired under section 6343(b) of the Internal Revenue Code of 1986 (without regard to this section) as of such date. III The right to a fair and just tax system 301. Waiver of user fee for installment agreements using automated withdrawals (a) In General Section 6159 is amended by redesignating subsections (e) and (f) as