2nd Circuit Rejects Firm’s ‘Bold Attempt’ to Contest IRS Levy
A law firm partner's advances on partnership profits are subject to administrative levies imposed by the Internal Revenue Service, the 2nd Circuit ruled Thursday, finding that advances, or partner "draws," at personal injury firm Moskowitz, Passman & Edelman constitute "salary or wages" under §6331(e) of the Internal Revenue Code. The firm will now have to pay the government nearly $1.5 million. The court said it was unpersuaded by Moskowitz Passman's "bold attempt to evade the levies."
