If a person liable to pay any tax fails to pay the tax after notice and demand for payment and notification of collection due process rights under section 6330, pursuant to section 6331, the Service may collect such tax by levy upon all property or rights to property belonging to such person.
An IOLTA would not be the property or belong to the attorney that holds it. Depending on how the tenant/landlord account is held, it may be a tougher call.
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