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Number: 199918010

Number: 199918010 2026

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The document is a memorandum from the Internal Revenue Service addressing the issue of whether a levy on a brokerage firm can reach stock and mutual fund shares when the firm does not possess physical certificates for those shares. It discusses the legal framework surrounding levies, particularly under I.R.C. § 6332, and concludes that the IRS must obtain actual stock certificates to effectively seize taxpayer property. The memorandum also touches on mutual funds and suggests that legislation may be needed to allow the IRS to directly receive cash for mutual fund shares upon levy.

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Begin by reviewing the document's sections, including the 'Issue' and 'Facts' areas, to understand the context of the levy on stock and mutual funds.
Fill in any required fields related to Taxpayer A and Brokerage Firm A, ensuring accuracy in details such as amounts and dates.
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