
From the U.S. Code Online via GPO Access
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[Laws in effect as of January 2, 2001]
[Document not affected by Public Laws enacted between
  January 2, 2001 and January 28, 2002]
[CITE: 26USC6334]

 
                     TITLE 26--INTERNAL REVENUE CODE
 
                Subtitle F--Procedure and Administration
 
                         CHAPTER 64--COLLECTION
 
        Subchapter D--Seizure of Property for Collection of Taxes
 
                              PART II--LEVY
 
Sec. 6334. Property exempt from levy


(a) Enumeration

    There shall be exempt from levy--

                (1) Wearing apparel and school books

        Such items of wearing apparel and such school books as are 
    necessary for the taxpayer or for members of his family;

        (2) Fuel, provisions, furniture, and personal effects

        So much of the fuel, provisions, furniture, and personal effects 
    in the taxpayer's household, and of the arms for personal use, 
    livestock, and poultry of the taxpayer, as does not exceed $6,250 in 
    value;

       (3) Books and tools of a trade, business, or profession

        So many of the books and tools necessary for the trade, 
    business, or profession of the taxpayer as do not exceed in the 
    aggregate $3,125 in value.

                      (4) Unemployment benefits

        Any amount payable to an individual with respect to his 
    unemployment (including any portion thereof payable with respect to 
    dependents) under an unemployment compensation law of the United 
    States, of any State, or of the District of Columbia or of the 
    Commonwealth of Puerto Rico.

                        (5) Undelivered mail

        Mail, addressed to any person, which has not been delivered to 
    the addressee.

              (6) Certain annuity and pension payments

        Annuity or pension payments under the Railroad Retirement Act, 
    benefits under the Railroad Unemployment Insurance Act, special 
    pension payments received by a person whose name has been entered on 
    the Army, Navy, Air Force, and Coast Guard Medal of Honor roll (38 
    U.S.C. 1562), and annuities based on retired or retainer pay under 
    chapter 73 of title 10 of the United States Code.

                     (7) Workmen's compensation

        Any amount payable to an individual as workmen's compensation 
    (including any portion thereof payable with respect to dependents) 
    under a workmen's compensation law of the United States, any State, 
    the District of Columbia, or the Commonwealth of Puerto Rico.

             (8) Judgments for support of minor children

        If the taxpayer is required by judgment of a court of competent 
    jurisdiction, entered prior to the date of levy, to contribute to 
    the support of his minor children, so much of his salary, wages, or 
    other income as is necessary to comply with such judgment.

      (9) Minimum exemption for wages, salary, and other income

        Any amount payable to or received by an individual as wages or 
    salary for personal services, or as income derived from other 
    sources, during any period, to the extent that the total of such 
    amounts payable to or received by him during such period does not 
    exceed the applicable exempt amount determined under subsection (d).

         (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) disability benefit under--
            (A) subchapter II, III, IV, V,,\1\ or VI of chapter 11 of 
        such title 38, or
---------------------------------------------------------------------------
    \1\ So in original.
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            (B) chapter 13, 21, 23, 31, 32, 34, 35, 37, or 39 of such 
        title 38.

               (11) Certain public assistance payments

        Any amount payable to an individual as a recipient of public 
    assistance under--
            (A) title IV or title XVI (relating to supplemental security 
        income for the aged, blind, and disabled) of the Social Security 
        Act, or
            (B) 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) Residences exempt in small deficiency cases and 
              principal residences and certain business assets 
              exempt in absence of certain approval or jeopardy

        (A) Residences in small deficiency cases

            If the amount of the levy does not exceed $5,000--
                (i) any real property used as a residence by the 
            taxpayer; or
                (ii) any real property of the taxpayer (other than real 
            property which is rented) used by any other individual as a 
            residence.

        (B) Principal residences and certain business assets

            Except to the extent provided in subsection (e)--
                (i) the principal residence of the taxpayer (within the 
            meaning of section 121); and
                (ii) tangible personal property or real property (other 
            than real property which is rented) used in the trade or 
            business of an individual taxpayer.

(b) Appraisal

    The officer seizing property of the type described in subsection (a) 
shall appraise and set aside to the owner the amount of such property 
declared to be exempt. If the taxpayer objects at the time of the 
seizure to the valuation fixed by the officer making the seizure, the 
Secretary shall summon three disinterested individuals who shall make 
the valuation.

(c) No other property exempt

    Notwithstanding any other law of the United States (including 
section 207 of the Social Security Act), no property or rights to 
property shall be exempt from levy other than the property specifically 
made exempt by subsection (a).

(d) Exempt amount of wages, salary, or other income

                   (1) Individuals on weekly basis

        In the case of an individual who is paid or receives all of his 
    wages, salary, and other income on a weekly basis, the amount of the 
    wages, salary, and other income payable to or received by him during 
    any week which is exempt from levy under subsection (a)(9) shall be 
    the exempt amount.

                          (2) Exempt amount

        For purposes of paragraph (1), the term ``exempt amount'' means 
    an amount equal to--
            (A) the sum of--
                (i) the standard deduction, 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, divided by

            (B) 52.

    Unless the taxpayer submits to the Secretary a written and properly 
    verified statement specifying the facts necessary to determine the 
    proper amount under subparagraph (A), subparagraph (A) shall be 
    applied as if the taxpayer were a married individual filing a 
    separate return with only 1 personal exemption.

             (3) Individuals on basis other than weekly

        In the case of any individual not described in paragraph (1), 
    the amount of the wages, salary, and other income payable to or 
    received by him during any applicable pay period or other fiscal 
    period (as determined under regulations prescribed by the Secretary) 
    which is exempt from levy under subsection (a)(9) shall be an amount 
    (determined under such regulations) which as nearly as possible will 
    result in the same total exemption from levy for such individual 
    over a period of time as he would have under paragraph (1) if 
    (during such period of time) he were paid or received such wages, 
    salary, and other income on a regular weekly basis.

(e) Levy allowed on principal residences and certain business assets in 
        certain circumstances

                      (1) Principal residences

        (A) Approval required

            A principal residence shall not be exempt from levy if a 
        judge or magistrate of a district court of the United States 
        approves (in writing) the levy of such residence.

        (B) Jurisdiction

            The district courts of the United States shall have 
        exclusive jurisdiction to approve a levy under subparagraph (A).

                     (2) Certain business assets

        Property (other than a principal residence) described in 
    subsection (a)(13)(B) shall not be exempt from levy if--
            (A) a district director or assistant district director of 
        the Internal Revenue Service personally approves (in writing) 
        the levy of such property; or
            (B) the Secretary finds that the collection of tax is in 
        jeopardy.

    An official may not approve a levy under subparagraph (A) unless the 
    official determines that the taxpayer's other assets subject to 
    collection are insufficient to pay the amount due, together with 
    expenses of the proceedings.

(f) Levy allowed on certain specified payments

    Any payment described in subparagraph (B) or (C) of section 
6331(h)(2) shall not be exempt from levy if the Secretary approves the 
levy thereon under section 6331(h).

(g) Inflation adjustment

                           (1) In general

        In the case of any calendar year beginning after 1999, each 
    dollar amount referred to in paragraphs (2) and (3) of subsection 
    (a) shall be increased by an amount equal to--
            (A) such dollar amount, multiplied by
            (B) the cost-of-living adjustment determined under section 
        1(f)(3) for such calendar year, by substituting ``calendar year 
        1998'' for ``calendar year 1992'' in subparagraph (B) thereof.

                            (2) Rounding

        If any dollar amount after being increased under paragraph (1) 
    is not a multiple of $10, such dollar amount shall be rounded to the 
    nearest multiple of $10.

(Aug. 16, 1954, ch. 736, 68A Stat. 784; Pub. L. 85-840, title IV, 
Sec. 406, Aug. 28, 1958, 72 Stat. 1047; Pub. L. 89-44, title VIII, 
Sec. 812(a), June 21, 1965, 79 Stat. 170; Pub. L. 89-719, title I, 
Sec. 104(c), Nov. 2, 1966, 80 Stat. 1137; Pub. L. 91-172, title IX, 
Sec. 945(a), Dec. 30, 1969, 83 Stat. 729; Pub. L. 94-455, title XII, 
Sec. 1209(a)-(c), title XIX, Sec. 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 
1709, 1710, 1834; Pub. L. 97-248, title III, Sec. 347(a), Sept. 3, 1982, 
96 Stat. 638; Pub. L. 98-369, div. B, title VI, Sec. 2661(o)(5), July 
18, 1984, 98 Stat. 1159; Pub. L. 99-514, title XV, Sec. 1565(a), Oct. 
22, 1986, 100 Stat. 2763; Pub. L. 100-647, title I, Sec. 1015(o), title 
VI, Sec. 6236(c), Nov. 10, 1988, 102 Stat. 3572, 3738; Pub. L. 102-83, 
Sec. 5(c)(2), Aug. 6, 1991, 105 Stat. 406; Pub. L. 104-168, title V, 
Sec. 502(a)-(c), July 30, 1996, 110 Stat. 1461; Pub. L. 104-193, title 
I, Sec. 110(l)(3), formerly Sec. 110(l)(6), Aug. 22, 1996, 110 Stat. 
2173, renumbered and amended Pub. L. 105-33, title V, Sec. 5514(a)(2), 
(3), Aug. 5, 1997, 111 Stat. 620; Pub. L. 105-34, title III, 
Sec. 312(d)(1), title X, Sec. 1025(a), Aug. 5, 1997, 111 Stat. 839, 924; 
Pub. L. 105-206, title III, Secs. 3431(a)-(c), 3445(a), (b), July 22, 
1998, 112 Stat. 758, 762, 763.)

 Adjustment of Applicable Dollar Value Amounts for Property Exempt From 
                       Levy for Calendar Year 2001

        For adjustment of applicable dollar value amounts under subsec. 
    (a)(2), (3) of this section for property exempt from levy for 
    calendar year 2001, see section 3.24 of Revenue Procedure 2001-13, 
    set out as a note under section 1 of this title.

                       References in Text

    The Railroad Retirement Act, referred to in subsec. (a)(6), is act 
Aug. 29, 1935, ch. 812, as amended generally by Pub. L. 93-445, title I, 
Sec. 101, Oct. 16, 1974, 88 Stat. 1305, known as the Railroad Retirement 
Act of 1974, which is classified generally to subchapter IV (Sec. 231 et 
seq.) of chapter 9 of Title 45, Railroads. For further details and 
complete classification of this Act to the Code, see Codification note 
set out preceding section 231 of Title 45, section 231t of Title 45, and 
Tables.
    The Railroad Unemployment Insurance Act, referred to in subsec. 
(a)(6), is act June 25, 1938, ch. 680, 52 Stat. 1094, as amended, which 
is classified principally to chapter 11 (Sec. 351 et seq.) of Title 45. 
For complete classification of this Act to the Code, see section 367 of 
Title 45 and Tables.
    The Social Security Act, referred to in subsecs. (a)(11)(A) and (c), 
is act Aug. 14, 1935, ch. 531, 49 Stat. 620, as amended. Titles IV and 
XVI of the Social Security Act are classified generally to subchapters 
IV (Sec. 601 et seq.) and XVI (Sec. 1381 et seq.), respectively, of 
chapter 7 of Title 42, The Public Health and Welfare. Section 207 of the 
Social Security Act is classified to section 407 of Title 42. For 
complete classification of this Act to the Code, see section 1305 of 
Title 42 and Tables.
    The Job Training Partnership Act, referred to in subsec. (a)(12), is 
Pub. L. 97-300, Oct. 13, 1982, 96 Stat. 1322, as amended, which was 
classified generally to chapter 19 (Sec. 1501 et seq.) of Title 29, 
Labor, and was repealed by Pub. L. 105-220, title I, Sec. 199(b)(2), 
Aug. 7, 1998, 112 Stat. 1059, effective July 1, 2000. Pursuant to 
section 2940(b) of Title 29, references to a provision of the Job 
Training Partnership Act, effective Aug. 7, 1998, are deemed to refer to 
that provision or the corresponding provision of the Workforce 
Investment Act of 1998, Pub. L. 105-220, Aug. 7, 1998, 112 Stat. 936, 
and effective July 1, 2000, are deemed to refer to the corresponding 
provision of the Workforce Investment Act of 1998. For complete 
classification of the Job Training Partnership Act to the Code, see 
Tables. For complete classification of the Workforce Investment Act of 
1998 to the Code, see Short Title note set out under section 9201 of 
Title 20, Education, and Tables.


                               Amendments

    1998--Subsec. (a)(2). Pub. L. 105-206, Sec. 3431(a), substituted 
``$6,250'' for ``$2,500''.
    Subsec. (a)(3). Pub. L. 105-206, Sec. 3431(b), substituted 
``$3,125'' for ``$1,250''.
    Subsec. (a)(13). Pub. L. 105-206, Sec. 3445(a), amended heading and 
text of par. (13) generally. Prior to amendment, text read as follows: 
``Except to the extent provided in subsection (e), the principal 
residence of the taxpayer (within the meaning of section 121).''
    Subsec. (e). Pub. L. 105-206, Sec. 3445(b), amended heading and text 
of subsec. (e) generally. Prior to amendment, text read as follows: 
``Property described in subsection (a)(13) shall not be exempt from levy 
if--
        ``(1) a district director or assistant district director of the 
    Internal Revenue Service personally approves (in writing) the levy 
    of such property, or
        ``(2) the Secretary finds that the collection of tax is in 
    jeopardy.''
    Subsec. (g)(1). Pub. L. 105-206, Sec. 3431(c)(1), substituted 
``1999'' for ``1997'' in introductory provisions.
    Subsec. (g)(1)(B). Pub. L. 105-206, Sec. 3431(c)(2), substituted 
``1998'' for ``1996''.
    1997--Subsec. (a)(11)(A). Pub. L. 105-33, Sec. 5514(a)(3), made 
technical amendment to directory language of Pub. L. 104-193, 
Sec. 110(l)(3). See 1996 Amendment note below.
    Subsec. (a)(13). Pub. L. 105-34, Sec. 312(d)(1), substituted 
``section 121'' for ``section 1034''.
    Subsecs. (f), (g). Pub. L. 105-34 added subsec. (f) and redesignated 
former subsec. (f) as (g).
    1996--Subsec. (a)(2). Pub. L. 104-168, Sec. 502(a), substituted 
``So'' for ``If the taxpayer is the head of a family, so'', ``the 
taxpayer's household'' for ``his household'', and ``$2,500'' for 
``$1,650 ($1,550 in the case of levies issued during 1989)''.
    Subsec. (a)(3). Pub. L. 104-168, Sec. 502(b), substituted ``$1,250'' 
for ``$1,100 ($1,050 in the case of levies issued during 1989)''.
    Subsec. (a)(11)(A). Pub. L. 104-193, Sec. 110(l)(3), formerly 
Sec. 110(l)(6), as renumbered and amended by Pub. L. 105-33, struck out 
``(relating to aid to families with dependent children)'' after ``title 
IV''.
    Subsec. (f). Pub. L. 104-168, Sec. 502(c), added subsec. (f).
    1991--Subsec. (a)(6). Pub. L. 102-83 substituted ``1562'' for 
``562''.
    1988--Subsec. (a)(2). Pub. L. 100-647, Sec. 6236(c)(1), substituted 
``$1,650 ($1,550 in the case of levies issued during 1989)'' for 
``$1,500''.
    Subsec. (a)(3). Pub. L. 100-647, Sec. 6236(c)(2), substituted 
``$1,100 ($1,050 in the case of levies issued during 1989)'' for 
``$1,000''.
    Subsec. (a)(10)(A). Pub. L. 100-647, Sec. 1015(o)(1), substituted 
``III, IV, V,'' for ``IV'' and added ``or'' at end.
    Subsec. (a)(10)(B), (C). Pub. L. 100-647, Sec. 1015(o)(2), (3), 
redesignated subpar. (C) as (B) and substituted ``13, 21, 23'' for 
``21'', and struck out former subpar. (B), which read as follows: 
``subchapter I, II, or III of chapter 19 of such title 38, or''.
    Subsec. (a)(11) to (13). Pub. L. 100-647, Sec. 6236(c)(4)(A), added 
pars. (11) to (13).
    Subsec. (d)(1). Pub. L. 100-647, Sec. 6236(c)(3)(A), amended par. 
(1) generally, striking out after introductory provisions the following 
definition of exempt amount:
        ``(A) $75, plus
        ``(B) $25 for each individual who is specified in a written 
    statement which is submitted to the person on whom notice of levy is 
    served and which is verified in such manner as the Secretary shall 
    prescribe by regulations and--
            ``(i) over half of whose support for the payroll period was 
        received from the taxpayer,
            ``(ii) who is the spouse of the taxpayer, or who bears a 
        relationship to the taxpayer specified in paragraphs (1) through 
        (9) of section 152(a) (relating to definition of dependents), 
        and
            ``(iii) who is not a minor child of the taxpayer with 
        respect to whom amounts are exempt from levy under subsection 
        (a)(8) for the payroll period.
    For purposes of subparagraph (B)(ii) of the preceding sentence, 
    `payroll period' shall be substituted for `taxable year' each place 
    it appears in paragraph (9) of section 152(a).''
    Subsec. (d)(2), (3). Pub. L. 100-647, Sec. 6236(c)(3)(B), added par. 
(2) and redesignated former par. (2) as (3).
    Subsec. (e). Pub. L. 100-647, Sec. 6236(c)(4)(B), added subsec. (e).
    1986--Subsec. (a)(10). Pub. L. 99-514 added par. (10).
    1984--Subsec. (c). Pub. L. 98-369 inserted ``(including section 207 
of the Social Security Act)''.
    1982--Subsec. (a)(2). Pub. L. 97-248, Sec. 347(a)(1), substituted 
``$1,500'' for ``$500''.
    Subsec. (a)(3). Pub. L. 97-248, Sec. 347(a)(2), substituted 
``$1,000'' for ``$250''.
    Subsec. (d)(1)(A). Pub. L. 97-248, Sec. 347(a)(3)(A), substituted 
``$75'' for ``$50''.
    Subsec. (d)(1)(B). Pub. L. 97-248, Sec. 347(a)(3)(B), substituted 
``$25'' for ``$15''.
    1976--Subsec. (a)(8). Pub. L. 94-455, Sec. 1209(c), substituted 
``Judgments for support of minor children'' for ``Salary, wages, or 
other income'' in heading.
    Subsec. (a)(9). Pub. L. 94-455, Sec. 1209(a), added par. (9).
    Subsec. (b). Pub. L. 94-455, Sec. 1906(b)(13)(A), struck out ``or 
his delegate'' after ``Secretary''.
    Subsec. (d). Pub. L. 94-455, Sec. 1209(b), added subsec. (d).
    1969--Subsec. (a)(8). Pub. L. 91-172 added par. (8).
    1966--Subsec. (a)(4). Pub. L. 89-719, Sec. 104(c)(1), struck out 
``or Territory'' after ``of any State''.
    Subsec. (a)(6), (7). Pub. L. 89-719, Sec. 104(c)(2), added pars. (6) 
and (7).
    1965--Subsec. (a)(5). Pub. L. 89-44 added par. (5).
    1958--Subsec. (a)(4). Pub. L. 85-840 added par. (4).

                         Change of Name

    Reference to United States magistrate or to magistrate deemed to 
refer to United States magistrate judge pursuant to section 321 of Pub. 
L. 101-650, set out as a note under section 631 of Title 28, Judiciary 
and Judicial Procedure.


                    Effective Date of 1998 Amendment

    Pub. L. 105-206, title III, Sec. 3431(d), July 22, 1998, 112 Stat. 
758, provided that: ``The amendments made by this section [amending this 
section] shall take effect with respect to levies issued after the date 
of the enactment of this Act [July 22, 1998].''
    Pub. L. 105-206, title III, Sec. 3445(d), July 22, 1998, 112 Stat. 
763, provided that: ``The amendments made by this section [amending this 
section] shall take effect on the date of the enactment of this Act 
[July 22, 1998].''


                    Effective Date of 1997 Amendments

    Amendment by section 312(d)(1) of Pub. L. 105-34 applicable to sales 
and exchanges after May 6, 1997, with certain exceptions, see section 
312(d) of Pub. L. 105-34, set out as a note under section 121 of this 
title.
    Section 1025(b) of Pub. L. 105-34 provided that: ``The amendment 
made by subsection (a) [amending this section] shall apply to levies 
issued after the date of the enactment of this Act [Aug. 5, 1997].''
    Amendment by Pub. L. 105-33 effective as if included in section 110 
of the Personal Responsibility and Work Opportunity Reconciliation Act 
of 1996, Pub. L. 104-193, at the time such section 110 became law, see 
section 5518(c) of Pub. L. 105-33, set out as a note under section 51 of 
this title.


                    Effective Date of 1996 Amendments

    Amendment by section 110(l)(3) of Pub. L. 104-193 effective July 1, 
1997, with transition rules relating to State options to accelerate such 
date, rules relating to claims, actions, and proceedings commenced 
before such date, rules relating to closing out of accounts for 
terminated or substantially modified programs and continuance in office 
of Assistant Secretary for Family Support, and provisions relating to 
termination of entitlement under AFDC program, see section 116 of Pub. 
L. 104-193, as amended, set out as an Effective Date note under section 
601 of Title 42, The Public Health and Welfare.
    Section 502(d) of Pub. L. 104-168 provided that: ``The amendments 
made by this section [amending this section] shall take effect with 
respect to levies issued after December 31, 1996.''


                    Effective Date of 1988 Amendment

    Section 1015(o) of Pub. L. 100-647 provided that the amendment made 
by that section is effective with respect to levies made after Dec. 31, 
1988.
    Amendment by section 6236(c) of Pub. L. 100-647 applicable to levies 
issued on or after July 1, 1989, see section 6236(h)(1) of Pub. L. 100-
647, set out as a note under section 6331 of this title.


                    Effective Date of 1986 Amendment

    Section 1565(b) of Pub. L. 99-514 provided that: ``The amendment 
made by this section [amending this section] shall apply to amounts 
payable after December 31, 1986.''


                    Effective Date of 1984 Amendment

    Amendment by Pub. L. 98-369 effective as though included in the 
enactment of the Social Security Amendments of 1983, Pub. L. 98-21, see 
section 2664(a) of Pub. L. 98-369, set out as a note under section 401 
of Title 42, The Public Health and Welfare.


                    Effective Date of 1982 Amendment

    Section 347(b) of Pub. L. 97-248 provided that: ``The amendments 
made by subsection (a) [amending this section] shall apply to levies 
made after December 31, 1982.''


                    Effective Date of 1976 Amendment

    Section 1209(e) of Pub. L. 94-455, as amended by Pub. L. 94-528, 
Sec. 2(c), Oct. 17, 1976, 90 Stat. 2483, provided that: ``The amendments 
made by this section [amending this section and sections 6331 and 6332 
of this title] shall apply only with respect to levies made after 
February 28, 1977.''


                    Effective Date of 1969 Amendment

    Section 945(b) of Pub. L. 91-172 provided that: ``The amendment made 
by subsection (a) [amending this section] shall apply with respect to 
levies made 30 days or more after the date of the enactment of this Act 
[Dec. 30, 1969].''


                    Effective Date of 1966 Amendment

    Amendment by Pub. L. 89-719 applicable after Nov. 2, 1966, 
regardless of when title or lien of United States arose or when lien or 
interest of another person was acquired, with certain exceptions, see 
section 114(a)-(c) of Pub. L. 89-719, set out as a note under section 
6323 of this title.


                    Effective Date of 1965 Amendment

    Section 812(b) of Pub. L. 89-44 provided that: ``The amendment made 
by subsection (a) [amending this section] shall take effect on the date 
of the enactment of this Act [June 21, 1965].''


                     State Fish and Wildlife Permits

    Pub. L. 105-206, title III, Sec. 3445(c), July 22, 1998, 112 Stat. 
763, provided that:
    ``(1) In general.--With respect to permits issued by a State and 
required under State law for the harvest of fish or wildlife in the 
trade or business of an individual taxpayer, the term `other assets' as 
used in section 6334(e)(2) of the Internal Revenue Code of 1986 shall 
include future income which may be derived by such taxpayer from the 
commercial sale of fish or wildlife under such permit.
    ``(2) Construction.--Paragraph (1) shall not be construed to 
invalidate or in any way prejudice any assertion that the privilege 
embodied in permits described in paragraph (1) is not property or a 
right to property under the Internal Revenue Code of 1986.''

                  Section Referred to in Other Sections

    This section is referred to in sections 6305, 6323, 6331 of this 
title; title 18 section 3613.
