Internal Revenue Bulletin: 2006-35
August 28, 2006
Levy on bank account. This ruling explains that a superpriority lien argument is not a defense to a levy. If a bank has such an argument, it must file a wrongful levy suit within nine months of the levy. Otherwise, the statute of limitations bars such a suit.
This notice effects interim revisions to Forms 8898, Statement for Individuals Who Begin or End Bona Fide Residence in a U.S. Possession, and 8840, Closer Connection Exception Statement for Aliens. Taxpayers required to file these forms should disregard certain line items. However, filers are reminded that they must retain the information elicited on those line items, as well as the rest of the form, in their books and records.
This document contains corrections to temporary regulations (T.D. 9262, 2006-24 I.R.B. 1040) concerning the application of section 199 of the Code, which provides a deduction for income attributable to domestic production activities, to certain transactions involving computer software.
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