Marty J. Meehan v. Commissioner

122 T.C. No. 23

UNITED STATES TAX COURT MARTY J. MEEHAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 219-02L. Filed June 14, 2004. Before the effective date of sec. 6330, I.R.C., R served a continuing wage levy on P’s employer. After the effective date of sec. 6330, I.R.C., R levied P’s severance pay pursuant to the continuing wage levy. Held: P’s severance pay constitutes “salary or wages” within the meaning of sec. 6331(e), I.R.C. Because the continuing wage levy was initiated before the effective date of sec. 6330, I.R.C., this Court lacks jurisdiction to review…