For instance, the requirement to keep grades at a certain level--Levy cuts money off if an heir's GPA dips below 3.0--may unfairly penalize heirs with learning disabilities.

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If he does, there is usually an automatic stay of the levy while he contests it, first at the IRS and then in Tax Court.

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Yet, the levy - if it is agreed - would apply to funds that were held with the banks at the end of Friday, rather than at the time of the vote.

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