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Section 6331(a) provides, in pertinent part:
If any person liable to pay any tax neglects or refuses
to pay the same * * *, it shall be lawful for the
Secretary to collect such tax * * * by levy upon all
property and rights to property(except such property as
is exempt under section 6334) belonging to such person
or on which there is a lien provided in this chapter
for the payment of such tax. * * *
Section 6334(a) exempts the following from levy: (1) Wearing
apparel and school books; (2) fuel, provisions, furniture, and
personal effects; (3) books and tools of a trade, business, or
profession; (4) unemployment benefits; (5) undelivered mail; (6)
certain annuity and pension payments; (7) workmen’s compensation;
(8) judgment for support of minor children; (9) certain amounts
of wages, salary and other income; (10) certain service-connected
disability payments; (11) certain public assistance payments;
(12) assistance under the job training partnership act (since
repealed); (13) certain residences. See also Iannone v.
Commissioner, supra at 293-294.
Section 6334(c) provides: “Notwithstanding any other law of
the United States * * *, no property or rights to property shall
be exempt from levy other than the property specifically made
exempt by subsection (a).” Section 301.6334-1(c), Proced. &
Admin. Regs., provides that “No provision of a State law may
exempt property or rights to property from levy for the
collection of any Federal tax.” See also Iannone v.
Commissioner, supra at 294.
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