[Federal Register Volume 59, Number 203 (Friday, October 21, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-26073]


[[Page Unknown]]

[Federal Register: October 21, 1994]


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DEPARTMENT OF THE TREASURY
Internal Revenue Service

26 CFR Part 301

[TD 8568]
RIN 1545-AN46

 

Property Exempt From Levy

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations.

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SUMMARY: This document contains final regulations regarding property 
exempt from levy. These regulations reflect changes made by the 
Technical and Miscellaneous Revenue Act of 1988 (TAMRA) and other 
public laws to section 6334 concerning the determination of property 
exempt from levy. The regulations affect taxpayers whose wages, salary, 
or other income are the subject of a levy by the Internal Revenue 
Service.

DATES: These regulations are effective October 21, 1994.
    These regulations apply to levies made on or after July 1, 1989.

FOR FURTHER INFORMATION CONTACT: Jerome D. Sekula, 202-622-3640 (not a 
toll-free call).

SUPPLEMENTARY INFORMATION:

Background

    This document contains final regulations amending the Procedure and 
Administration Regulations (26 CFR part 301) under section 6334 of the 
Internal Revenue Code (Code). The regulations reflect the amendment of 
section 6334 by sections 1015(o) and 6236(c) of the Technical and 
Miscellaneous Revenue Act of 1988, Public Law. 100-647, as well as the 
Tax Reform Act of 1986, Public Law 99-514, the Tax Equity and Fiscal 
Responsibility Act of 1982, Public Law 97-248, and the Tax Reform Act 
of 1976, Public Law 94-455, which had not previously been reflected in 
the regulations.
    On May 27, 1992, a notice of proposed rulemaking relating to 
property exempt from levy was published in the Federal Register (57 FR 
22189). Written comments responding to this notice were received. No 
public hearing was requested or held. After consideration of all the 
comments, the proposed regulations under section 6334 are adopted as 
revised by this Treasury decision.

Explanation of Revisions and Summary of Comments

    One commentator suggested that the final regulations provide that 
all retirement plans be exempt from levy, not only those plans 
enumerated in section 6334 of the Code. This suggestion is not adopted. 
Congress has specifically provided that certain property is exempt from 
levy. In fact, section 6334(c) provides that no property is exempt from 
levy other than property specifically enumerated in the Code.
    The proposed regulations provide that where an individual is paid 
or receives wages, salary, or other income on a one- time basis, the 
exempt amount is computed as if the taxpayer had been paid for the one-
week period ending on the day of payment. One commentator raised 
questions concerning the application of this ``one time basis'' rule 
where an individual was paid on a recurrent, but irregular, basis. 
Another commentator questioned whether the proposed rule is a correct 
interpretation of section 6334(d)(3). This commentator argued that 
under section 6334(d)(3) the exemption amount should be calculated 
using the total time period over which the wages, salary, or other 
income was earned.
    The proposed regulations have been revised to address the concerns 
of these commentators. Under the final regulations, when taxpayers are 
paid on a one-time basis or are paid on a recurrent, but irregular, 
basis which does not comport with an established calendar period 
regularly used by the employer or other person being levied upon, 
taxpayers are entitled to the exempt amount for each week to which the 
payment received is attributable.
    One commentator raised a concern regarding levies that span more 
than one calendar year where the standard deduction or the amount of 
the personal exemption changes by operation of law (such as by indexing 
or otherwise). Under the proposed regulations, the exempt amount 
remains the same in the second year. The commentator stated that this 
could cause hardship for employers with automated payroll systems 
because those employers might have to maintain separate, manual 
accounts for those employees who had been levied upon in a preceding 
year. The commentator suggested that employers should be required to 
calculate and use the new exempt amount when a change in the standard 
deduction amount or personal exemption amount occurs by operation of 
law.
    While the suggested change might be beneficial to some employers, 
the Service and Treasury are concerned that it could result in a 
hardship to other employers (particulary smaller employers) who would 
be required to reexamine the statement of each employee who files for 
exemption and recompute a new exempt amount each time a change in the 
law occurs. In order to accommodate these conflicting concerns, under 
the final regulations a taxpayer may submit a new verified statement to 
his or her employer to claim a new exempt amount based on law changes 
effective in the year in which the claim is filed. This permits a 
taxpayer to claim an additional exempt amount but avoids burdening 
businesses with the requirement to reexamine the statement of each 
employee who files for exemption and automatically recompute a new 
exempt amount based on law changes alone. However, employers who wish 
to use the new exempt amount can request that their employees submit 
new verified statements in order to recompute new exempt amounts based 
on the changes in the law.
    Under the proposed regulations, when payments are made on the basis 
of a daily pay period, the exempt amount is calculated on the basis of 
360 days. The final regulations provide that the exempt amount is 
calculated on the basis of 260 days, the number of work days in a year 
(assuming a five day work week and 52 work weeks in a year). This 
change increases the exempt amount available to a taxpayer who works on 
a daily pay-period basis. The Service and Treasury believe that this 
change is consistent with the requirement of section 6334(d)(3) of the 
Code.

Effective Date

    These regulations are effective for levies made on or after July 1, 
1989. However, any reasonable attempt to comply with the statutory 
amendments addressed by these regulations prior to February 21, 1995 
will be considered as meeting the requirements of these regulations.

Special Analyses

    It has been determined that this Treasury decision is not a 
significant regulatory action as defined in EO 12866. Therefore, a 
regulatory assessment is not required. It also has been determined that 
section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) 
and the Regulatory Flexibility Act (5 U.S.C. chapter 6) do not apply to 
these regulations, and therefore, a Regulatory Flexibility Analysis is 
not required. Pursuant to section 7805(f) of the Code, the notice of 
proposed rulemaking was submitted to the Small Business Administration 
for comment on its impact on small business.

Drafting Information

    The principal author of these final regulations is Jerome D. 
Sekula, Office of the Assistant Chief Counsel (General Litigation), 
IRS. However, personnel from other offices of the Internal Revenue 
Service and Treasury Department participated in their development.

List of Subjects in 26 CFR Part 301

    Employment taxes, Estate taxes, Excise taxes, Gift taxes, Income 
taxes, Penalties, Reporting and recordkeeping requirements.

Adoption of Amendments to the Regulations

    Accordingly, 26 CFR part 301 is amended as follows:

PART 301--[AMENDED]

    Paragraph 1. The authority citation for part 301 continues to read 
in part as follows:

    Authority: 26 U.S.C. 7805 * * *

    Par. 2. Section 301.6334-1 is amended as follows:
    1. In paragraph (a)(2), in the first sentence, ``$500'' is removed 
and ``$1,650 ($1,550 for levies issued prior to January 1, 1990)'' 
added in its place.
    2. In paragraph (a)(3), ``$250'' is removed and ``$1,100 ($1,050 
for levies issued prior to January 1, 1990)'' added in its place.
    3. In paragraph (a)(8), the last sentence is removed.
    4. In paragraph (a)(9), ``Sec. 301.6334-6'' is removed and 
``Sec. 301.6334-4'' added in its place.
    5. Paragraphs (a)(10) through (a)(13), (d) and (e) are added to 
read as follows:


Sec. 301.6334-1  Property exempt from levy.

    (a) * * *
    (10) Certain service-connected disability payments. Any amount 
payable to an individual as a service-connected (within the meaning of 
section 101(16) of title 38, United States Code (U.S.C.)) disability 
benefit under--
    (i) Subchapters II (wartime disability compensation), III (wartime 
death compensation), IV (peacetime disability compensation), V 
(peacetime death compensation), or VI (general compensation provisions) 
of chapter 11 of title 38, U.S.C.; or
    (ii) Chapters 13 (dependency and indemnity compensation for service 
commenced deaths), 21 (specially adapted housing for disabled 
veterans), 23 (burial benefits), 31 (vocational rehabilitation), 32 
(post-Vietnam era veterans' educational assistance), 34 (veterans' 
educational assistance), 35 (survivors' and dependents' educational 
assistance), 37 (home, condominium, and mobile home loans), or 39 
(automobiles and adaptive equipment for certain disabled veterans and 
members of the armed forces) of title 38, U.S.C.
    (11) Certain public assistance payments. Any amount payable to an 
individual as a recipient of public assistance under--
    (i) Title IV (relating to aid to families with dependent children) 
or title XVI (relating to supplemental security income for the aged, 
blind, and disabled) of the Social Security Act (42 U.S.C. 301 et 
seq.); or
    (ii) State or local government public assistance or public welfare 
programs for which eligibility is determined by a needs or income test.
    (12) Assistance under Job Training Partnership Act. Any amount 
payable to a participant under the Job Training Partnership Act (29 
U.S.C. 1501 et. seq.) from funds appropriated pursuant to such Act.
    (13) Principal residence exempt in absence of certain approval or 
jeopardy. Except to the extent provided in section 6334(e), the 
principal residence (within the meaning of section 1034) of the 
taxpayer whose tax liability is being sought to be collected upon.
* * * * *
    (d) Levy allowed on principal residence. The principal residence of 
the taxpayer is not exempt from levy if--
    (1) A district director or an assistant district director 
personally approves, in writing, the levy on such property; or
    (2) The district director determines that the collection of tax is 
in jeopardy.
    (e) Effective date. These provisions are effective with respect to 
levies made on or after July 1, 1989. However, any reasonable attempt 
by a taxpayer to comply with the statutory amendments addressed by 
these regulations prior to February 21, 1995 will be considered as 
meeting the requirements of these regulations.
    Par. 3. Sections 301.6334-2, 301.6334-3 and 301.6334-4 are revised 
to read as follows:


Sec. 301.6334-2  Wages, salary, and other income.

    (a) In general. Under section 6334 (a)(9) and (d) certain amounts 
payable to or received by a taxpayer as wages, salary, or other income 
are exempt from levy. This section describes the income of a taxpayer 
that is eligible for the exemption from levy (paragraph (b) of this 
section) and how exempt amounts are to be paid to the taxpayer 
(paragraph (c) of this section). Section 301.6334-3 describes that sum 
that will be exempt from levy for each of the taxpayer's pay periods. 
Pay periods are described in Sec. 301.6334-3. For the amounts exempt 
from levy, see Sec. 301.6334-3.
    (b) Eligible taxpayer income. Only wages, salary, or other income 
payable to the taxpayer after the levy is made on the payor may be 
exempt from levy under section 6334(a)(9). No amount of wages, salary, 
or other income that is paid to the taxpayer before levy is made on the 
payor will be so exempt from levy under section 6334(a)(9). The 
provisions of this paragraph (b) may be illustrated by the following 
example:

    Example. Delinquent taxpayer A, an individual, is employed by 
the M Corporation and is paid wages on Friday of each week. 
Accordingly, A is paid wages on Friday, February 16, 1990. On 
Saturday, February 17, A deposits these wages into his personal 
checking account at Bank N. On Tuesday, February 20, a notice of 
levy is served on the M Corporation and also on Bank N. Amounts 
payable to A as wages on Friday, February 23, 1990, and any payday 
thereafter may be exempt from levy under section 6334(a)(9). No 
amount of wages A deposited in his account at Bank N on February 17, 
1990, is exempt from levy under section 6334(a)(9).

    (c) Payment of exempt amounts to taxpayer--(1) From wages, salary, 
or income from other sources where levy on all sources not made. In the 
case of a taxpayer who has more than one source of wages, salary, or 
other income, the district director may elect to levy on only one or 
more sources while leaving other sources of income free from levy. If 
the wages, salary, or other income that the district director leaves 
free from levy equal or exceed the amount to which the taxpayer is 
entitled as an exemption from levy under section 6334(a)(9), computed 
in accordance with Sec. 301.6334-3 (and are not otherwise exempt), the 
district director may treat no amount of the taxpayer's wages, salary, 
or other income on which the district director elects to levy as exempt 
from levy. In such a case, the district director must notify the 
employer or other person upon whom the levy is served that no amount of 
the taxpayer's wages, salary, or other income is exempt from levy. The 
employer or other person upon whom the levy is served may rely on such 
notification in paying over amounts pursuant to the levy. In the 
absence of such notification from the district director, however, the 
employer or other person upon whom the levy is served must determine 
the amount exempt from levy pursuant to Sec. 301.6334-3 as if that 
employer or other person upon whom the levy is served is the only 
source of wages, salary, or other income. Amounts not exempt from levy 
are to be paid to the district director in accordance with the terms of 
the levy. The provisions of this paragraph (c)(1) may be illustrated by 
the following example:

    Example. Delinquent taxpayer C is an employee of O Corporation 
and is paid wages totalling $450 on Friday of each week. C also 
performs services for P Corporation and is paid a salary of $250 on 
Friday of each week. On Tuesday, February 20, 1990, a levy is served 
on O Corporation with respect to the wages payable to C. A levy is 
not served on P Corporation. C's filing status is single and C is 
entitled to 1 personal exemption. Under Sec. 301.6334-3, C is 
entitled to an exemption from levy under 6334(a)(9) totalling 
$101.92 for each weekly pay period. However, because levy has not 
been made on C's salary paid by the P Corporation ($250 per week) 
and that salary exceeds the weekly amount ($101.92) to which C is 
entitled as exempt from levy, the district director may treat no 
amount of C's wages paid by the O Corporation as exempt from levy. 
If the district director requires such treatment, the district 
director must notify O Corporation that no amount of C's wages is 
exempt from levy and O Corporation may rely on such notification; in 
the absence of such notification O Corporation must treat $101.92 as 
exempt from levy.

    (2) Where sources not levied upon are less than exempt amount. If 
the taxpayer's income upon which the district director does not levy is 
less than the amount to which the taxpayer is entitled as exempt from 
levy, then an additional amount, determined to be exempt from levy 
pursuant to Sec. 301.6334-3, may be paid to the taxpayer from the 
sources of wages, salary, or other income upon which levy has been 
made. In such a case, the district director must designate those wages, 
salary, or other income from which the exempt amount is to be paid to 
the taxpayer, and must notify the employer or other person upon whom 
the levy is served of the amount of the taxpayer's wages, salary, or 
other income that is exempt from levy. The employer or other person may 
rely on such notification in paying over amounts pursuant to the levy. 
In the absence of such notification from the district director, the 
employer or other person upon whom the levy is served must determine 
the amount exempt from levy pursuant to Sec. 301.6334-3 as if that 
employer or other person upon whom the levy is served is the only 
source of wages, salary, or other income. Amounts not exempt from levy 
are to be paid to the district director in accordance with the terms of 
the levy. The provisions of this paragraph (c)(2) may be illustrated by 
the following example:

    Example. Delinquent taxpayer C is an employee of O Corporation 
and is paid wages totalling $50 on Friday of each week. C also 
performs services for P Corporation and is paid a salary of $75 on 
Friday of each week. On Tuesday, February 20, 1990, a levy is served 
on P Corporation with respect to the wages and salary of C. C's 
filing status is single and C is entitled to 1 personal exemption. 
Under Sec. 301.6334-3, C is entitled to an exemption from levy under 
section 6334(a)(9) totalling $101.92 for each weekly pay period. The 
district director may notify P Corporation that only $51.92 of C's 
wages is exempt from levy and P Corporation may rely on such 
notification; in the absence of such notification, P Corporation 
must treat the entire $75 salary as exempt from levy.

    (d) Effective date. These provisions are effective with respect to 
levies made on or after July 1, 1989. However, any reasonable attempt 
by a taxpayer to comply with the statutory amendments addressed by 
these regulations prior to February 21, 1995 will be considered as 
meeting the requirements of these regulations.


Sec. 301.6334-3  Determination of exempt amount.

    (a) Individuals paid on weekly basis. In the case of any individual 
who is paid or receives all of his or her wages, salary, and other 
income on a weekly basis, the amount of wages, salary, and other income 
payable to or received by him or her during any week that is exempt 
from levy under section 6334(a)(9) is the exempt amount.
    (b) Term defined. The term exempt amount means an amount equal to--
    (1) The sum of--
    (i) The standard deduction (including additional standard 
deductions on account of age or blindness); and
    (ii) The aggregate amount of the deductions for personal exemptions 
allowed the taxpayer under section 151 in the taxable year in which 
such levy occurs;
    (2) Divided by 52.
    (c) Written and properly verified statement. Unless the taxpayer 
submits to the employer for forwarding to the district director a 
written and properly verified statement (as described in Sec. 301.6334-
4) specifying the facts necessary to determine the proper amount under 
paragraphs (b)(1) (i) and (ii) of this section, paragraphs (b)(1) (i) 
and (ii) of this section must be applied as if the taxpayer were a 
married individual filing a separate return with only 1 personal 
exemption.
    (d) Individuals paid on basis other than weekly--(1) In general. In 
the case of an individual who is paid or receives wages, salary, and 
other income other than on a weekly basis, the amount payable to that 
individual during any applicable pay period that is exempt from levy 
under section 6334(a)(9) is the amount that as nearly as possible will 
result in the same total exemption from levy for such individual over 
that period of time other than weekly as that to which the individual 
would have been entitled under paragraph (b) of this section if, during 
such period of time, the individual were paid or received such wages, 
salary, and other income on a regular weekly basis.
    (2) Specific pay periods other than weekly. In the case of wages, 
salary, or other income paid to an individual on the basis of an 
established calendar period regularly used by the employer or other 
person levied upon for payroll or payment purposes, the exempt amount 
of wages, salary, and other income payable to or received by an 
individual during an applicable pay period other than weekly equals--
    (i) The sum of--
    (A) The standard deduction (including additional standard 
deductions on account of age or blindness); and
    (B) The aggregate amount of the deductions for personal exemptions 
allowed the taxpayer under section 151 in the taxable year in which 
such levy occurs;
    (ii) Divided by--
    (A) 260 in the case of a daily pay period;
    (B) 26 in the case of a bi-weekly pay period;
    (C) 24 in the case of a semi-monthly pay period; and
    (D) 12 in the case of a monthly pay period.
    (3) Nonspecific pay periods. In the case of wages, salary, or other 
income paid to an individual on a one-time or a recurrent but irregular 
basis and which is not paid on the basis of an established calendar 
period regularly used by the employer or other person levied upon for 
payroll or payment purposes, the exempt amount of wages, salary, and 
other income payable to or received by an individual equals the exempt 
amount defined in paragraph (b) of this section multiplied by the 
number (but not more than 52) of full weeks (consisting of seven 
calendar days) to which such payment is attributable. The provisions of 
this paragraph (d)(3) may be illustrated by the following example:

    Example. Taxpayer A's exempt amount per week (as determined 
under paragraph (b) of this section) is $100. Taxpayer A is hired by 
Corporation X to perform a specific task for Corporation X at a flat 
fee of $1,500 which is to be paid at the completion of the task. 
Taxpayer A completes the task in 10 weeks. The total exempt amount 
is $1,000 and $500 is subject to levy.

    (e) Levies continuing into following years. The exempt amount is 
computed on the basis of the standard deduction (including additional 
standard deductions on account of age or blindness) for the taxpayer's 
filing status and the amount of the deduction for a personal exemption 
in effect in the taxable year in which the original notice of levy is 
served. Unless the taxpayer submits a new verified statement in 
accordance with Sec. 301.6334-4, the exempt amount remains the same for 
pay periods following the pay period in which the notice of levy is 
served even if there is a change in the taxpayer's factual situation or 
a change by operation of law (such as by indexing or otherwise) to the 
standard deduction or personal exemption amounts.
    (f) Effective date. These provisions are effective with respect to 
levies made on or after July 1, 1989. However, any reasonable attempt 
by a taxpayer to comply with the statutory amendments addressed by 
these regulations prior to February 21, 1995 will be considered as 
meeting the requirements of these regulations.


Sec. 301.6334-4  Verified statements.

    (a) In general. For purposes of Secs. 301.6334-2 and 301.6334-3, 
the amount of wages, salary, or other income that is exempt from levy 
must be determined on the basis of a written and properly verified 
statement submitted by the taxpayer to his or her employer for 
submission to the district director specifying the facts necessary to 
determine the standard deduction and the aggregate amount of the 
deductions for personal exemptions allowed the taxpayer under section 
151 in the taxable year in which the levy is served. In the absence of 
submission of such statement, the amount that is exempt from levy must 
be determined as if the taxpayer were a married individual filing a 
separate return with only 1 personal exemption.
    (b) Content of statement. The statement in paragraph (a) of this 
section must be a written statement signed under penalty of perjury, 
and dated, containing the following information--
    (1) The filing status of the taxpayer as either:
    (i) Single;
    (ii) Married filing a joint return;
    (iii) Married filing a separate return;
    (iv) Head of household; or
    (v) Qualifying widow or widower with dependent child;
    (2) The name, relationship, and Social Security Number of each 
individual whom the taxpayer can claim as a personal exemption on the 
taxpayer's income tax return; and
    (3) Any additional standard deductions that the taxpayer can claim 
on account of age (65 or older) or blindness on the taxpayer's income 
tax return.
    (c) Submission of verified statement--(1) Obligation of employer. 
An employer upon whom a notice of levy for wages, salary, or other 
income of a taxpayer is served must promptly notify the taxpayer of the 
fact that a notice of levy has been served. Unless otherwise indicated 
on the face of the notice of levy, the employer must request the 
taxpayer to provide the employer with a written statement signed under 
penalty of perjury, and dated, containing the information set forth in 
paragraph (b) of this section, and this statement must be submitted by 
the employer to the district director. The employer must submit this 
statement to the district director at the time the employer first 
responds to the notice of levy.
    (2) Submission by taxpayer. The taxpayer must provide the employer 
upon whom the notice of levy has been served with a verified statement 
complying with paragraph (b) of this section. Unless the taxpayer 
provides a verified statement, the amount that is exempt from levy must 
be determined as if the taxpayer were a married individual filing a 
separate return with only 1 personal exemption.
    (3) Additional statements. A taxpayer may submit a verified 
statement to his or her employer at any time. Except as otherwise 
provided in paragraph (d) of this section, such verified statement will 
be effective for any payment of wages, salary, or other income made 
after the date of submission and will replace any previously submitted 
verified statement. The employer must provide the district director 
with the statement on the next occasion on which the employer responds 
to the notice of levy.
    (d) Effect of verified statement--(1) A verified statement 
submitted by an employee is effective upon receipt by the employer, and 
the employer is required to compute the exempt amount on the basis of 
the information contained in the verified statement unless notified to 
the contrary by the Internal Revenue Service.
    (2) The Internal Revenue Service may find that a verified statement 
submitted by an employee contains a materially incorrect statement, or 
it may determine, after written request to the employee for 
verification of information contained in the verified statement, that 
it lacks sufficient information to determine whether the verified 
statement is correct. If the Internal Revenue Service so finds or 
determines, and notifies the employer in writing that the verified 
statement is defective, upon receipt of such notice the employer shall 
consider the verified statement to be defective for purposes of 
computing the exempt amount.
    (3) If the Internal Revenue Service notifies the employer that the 
verified statement is defective, the Internal Revenue Service will, 
based upon its finding, advise the employer that the employer is to 
compute the exempt amount as if no verified statement had been 
submitted by the employee or will describe upon what basis the exempt 
amount is to be computed. The Internal Revenue Service will also 
specify which Internal Revenue Service office to contact for further 
information.
    (4) In addition to any notice furnished to the employer for the 
employer's use, the Internal Revenue Service will provide the employer 
with a copy for the employee of each notice it furnishes the employer.
    (5) The employer must promptly furnish the employee with a copy of 
any Internal Revenue Service notice with respect to a verified 
statement submitted by the employee.
    (6) Once paragraph (d)(3) of this section applies, the employer 
must continue to compute the exempt amount on the basis of the written 
notice from the Internal Revenue Service until the Internal Revenue 
Service by written notice advises the employer to compute the exempt 
amount on the basis of a new verified statement (as described in 
paragraph (d)(7) of this section) and revokes its earlier written 
notice.
    (7) Once paragraph (d)(3) of this section applies, the employee may 
submit a new verified statement together with a written explanation of 
any circumstances of the employee which have changed since the Internal 
Revenue Service's earlier written notice, or any other circumstances or 
reasons as justification or support for the claims made by the employee 
on the new verified statement. The employee may submit the new verified 
statement and written explanation either--
    (i) To the Internal Revenue Service office specified in the notice 
furnished to the employer under paragraph (d)(3) of this section; or
    (ii) To the employer, who must forward the new verified statement 
and written explanation to the Internal Revenue Service office 
specified in the notice earlier furnished to the employer on the next 
occasion on which the employer responds to the notice of levy.
    (e) Effective date. These provisions are effective with respect to 
levies made on or after July 1, 1989. However, any reasonable attempt 
by a taxpayer to comply with the statutory amendments addressed by 
these regulations prior to February 21, 1995 will be considered as 
meeting the requirements of these regulations.


Secs. 301.6334-5, 301.6334-6 and 301.6334-7  [Removed]

    Par. 4. Sections 301.6334-5 through 301.6334-7 are removed.

    Approved: October 4, 1994.
Margaret Milner Richardson,
Commissioner of Internal Revenue.
Leslie Samuels,
Assistant Secretary of the Treasury.
[FR Doc. 94-26073 Filed 10-20-94; 8:45 am]
BILLING CODE 4830-01-U