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creditors to proceed against the pension benefits at issue. Id.
at 659. In rejecting this premise, the court stated: “ERISA’s
anti-alienation provision plainly does not preempt the operation
of California law” because “ERISA itself has a saving clause that
states: ‘Nothing in this subchapter [which includes the anti-
alienation provision] shall be construed to alter, amend, modify,
invalidate, impair, or supersede any law of the United States.’”
Id. at 659, 660 (insertion in original).
McIntyre is distinguishable from this case. First, McIntyre
deals with ERISA and not section 6015. Second, section 6015(a)
and (g), unlike ERISA, expressly preempts community property law.
Sec. 6015(a) (section 6015 determinations are made “without
regard to community property laws”), (g) (refunds are made
“notwithstanding any other law or rule of law (other than section
6511, 6512(b), 7121, or 7122)”). Third, section 6015 has no
saving clause like ERISA.
b. Section 6015 Was Enacted Later
Even if section 6015 and section 6321 are in conflict,
section 6015 controls because section 6015 was enacted later than
section 6321 and supersedes section 6321 insofar as the two
sections are in conflict. See McLean Trucking Co. v. United
States, 321 U.S. 67, 79 (1944); Adkins v. Arnold, 235 U.S. 417,
421 (1914); Specking v. Commissioner, 117 T.C. 95, 116 (2001),
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