CCA 200914052
Civil Actions by Persons Other Than Taxpayers
ID: CCA_2009030409554747 Number: 200914052
Release Date: 4/3/2009
Office: ---
UILC: 6402.00-00, 6343.00-00, 7426.00-
00
From: ---
Sent: Wednesday, March 04, 2009 9:55:53 AM
To: ---
Cc:
Subject: RE: 6402(e) and perhaps priority and perhaps levy ---
Unfortunately, priority would not come into play for purposes of entitlement to the overpayment. The state could have brought a wrongful levy claim, however, under 6343(b) and/or 7426, based upon its priority (and still can if we are within 9 months of the levy).
Source: view the official PDF
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