Ezel / IRS Rulings / 201919014

Bank account was not exempt from levy

Number
201919014
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Types of Property
Topics
Procedure, penalties, and administration
Code sections
§ 6334
Ruling dated
April 18, 2019
Publicly released
May 10, 2019
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 2019, 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 2019
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

In a brief email responding to an informal section 6334 question, Chief Counsel confirmed that the bank account at issue was not exempt from levy. The public release contains only that conclusion and does not disclose the taxpayer, the account’s characteristics, the asserted exemption, or any supporting factual or legal analysis.

Ruling snapshot

  • Question: Was the bank account exempt from levy under section 6334?
  • Outcome: advice given: no
  • Key authority: IRC § 6334

Full text (IRS public release)

ID:      CCA_2019041814231120
UILC:    6334.01-00

Number: 201919014
Release Date: 5/10/2019
From:
Sent: Thursday, April 18, 2019 2:23:11 PM
To:
Cc:
Bcc:
Subject: RE: Informal Question re IRC § 6334




What I said in the voice message is that we agree that the bank account is not exempt
from levy.

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