Number: 199918010 2025

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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, including the necessity of physical possession of stock certificates for effective seizure. The memorandum concludes that while the IRS can direct a broker to obtain actual certificates upon serving a levy, it cannot sell seized stock on an exchange. Additionally, it highlights challenges related to mutual funds and recommends legislative changes to improve the IRS's ability to collect owed taxes.

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