A tax levy under United States federal law is an administrative action by the Internal Revenue Service (IRS) under statutory authority, generally without going to court, to seize property to satisfy a tax liability. The levy "includes the power of distraint and seizure by any means". The general rule is that no court permission is required for the IRS to execute a tax levy. While the government relies mainly on voluntary payment of tax, it retains the power of levy to collect involuntarily from those who persistently refuse to pay. The IRS can levy upon wages, bank accounts, social security payments, accounts receivables, insurance proceeds, real property, and, in some cases, a personal residence. Under Internal Revenue Code section 6331, the Internal Revenue Service can "levy upon all property and rights to property" of a taxpayer who owes Federal tax. The IRS can levy upon assets that are in the possession of the taxpayer, called a seizure, or it can levy upon assets in the possession of a third party, a bank, a brokerage house, etc. All future statutory references will be to the Internal Revenue Code unless noted otherwise. Procedural requirements According to the U.S. Supreme Court, the power of administrative levy for federal taxes dates back to the year 1791. The Fifth Amendment of the Constitution forbids the government (whether state or federal) from taking an individual's property without due process of law. This rule applies to an IRS levy. To comply with the U.S. Constitution, the IRS must provide the taxpayer notice of the coming levy and an opportunity to be heard. Under §6330(a)(2), the IRS must send to the taxpayer a notice by either personal hand delivery, or through certified mail, or left at the taxpayer's usual place of business. The notice must arrive at least thirty days prior to the levy taking place. However, if the taxpayer is planning to depart from the United States, or conceal himself or herself; planning to place his or her property beyond the reach of a commissioner by concealing it, by dissipating it, or by transferring it to other persons; or financially imperiled, under 26 U.S.C. § 6331(a), the IRS may determine the collection of the tax is in jeopardy and may immediately make a levy after serving notice and demand for payment of the tax. In such cases, notice of the jeopardy levy need not be served upon