The Service seized a married couple’s brokerage account for the payment of back taxes. The couple felt the stock market would fall and asked the Service to sell the shares at a time when the value of the shares was greater than their tax debt. The IRS delayed for many months before selling. In fact, the account value fell dramatically to a point where it was less than the tax debt. The couple filed in Tax Court and the Court agreed that the Service had to credit the couple with the value of the stock 60 days after the taxpayers gave the okay to sell. The Ninth Circuit Court of Appeals agreed. The IRS says they disagree with the rulings and will not follow the ruling except in states covered by the Ninth Circuit Court of Appeals.