Ezel / IRS Rulings / 201550037

Levy does not reach contract payments that are not yet due

Number
201550037
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
LEVY
Topics
Income and deductions
Code sections
§ 6331
Ruling dated
October 22, 2015
Publicly released
December 11, 2015
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2015, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2015
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel confirmed the position stated in CCA 199930003 and agreed that the government should concede the issue in the pending case. The levy did not reach payments that a third party might make to the taxpayer under a contract when those payments were not yet due.

Ruling snapshot

  • Question: Did the levy reach contract payments that the third party did not yet owe to the taxpayer?
  • Outcome: Advice given
  • Key authorities: IRC § 6331; CCA 199930003

Full text (IRS public release)

ID: CCA-10220413-15 [Third Party Communication:

UILC: 50.00.00-0 Date of Communication: Month DD, YYYY]

Number: 201550037
Release Date: 12/11/2015
From: ---------------------
Sent: Thursday, October 22, 2015 4:13 PM
To: ---------------------------
Bcc:
Subject: FW: CCA 199930003 levy

-------------,

CCA 199930003 properly states our position and we agree with you that we should concede that the levy
in your case does not reach payments not yet due to the taxpayer under the contract with the third
party.

Attachment

CCA 199930003 (1999)

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