122 T.C. No. 23
UNITED STATES TAX COURT
MARTY J. MEEHAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 219-02L. Filed June 14, 2004.
Before the effective date of sec. 6330, I.R.C., R
served a continuing wage levy on P’s employer. After
the effective date of sec. 6330, I.R.C., R levied P’s
severance pay pursuant to the continuing wage levy.
Held: P’s severance pay constitutes “salary or
wages” within the meaning of sec. 6331(e), I.R.C.
Because the continuing wage levy was initiated before
the effective date of sec. 6330, I.R.C., this Court
lacks jurisdiction to review R’s levy of P’s severance
pay.
Daniel J. Arno, for petitioner.
Anne D. Melzer, for respondent.
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