It appears that the IRS can not grab an LLC’s assets for taxes owed by its sole member, according to the agency.
Even if a one-member LLC is disregarded from its owner for federal tax purposes, that status does not apply for tax collection purposes because the member has no ownership interest in the LLC’s assets under state law.
The IRS might allow a levy for LLC payouts that are based on the owner’s interest in the entity…for example, if income from the LLC is the owner’s source of support. But it can tap a merchant’s credit card reserve account, according to a memo that was sent to field agents. The Service can not force a distribution from the account. It must wait for a payout to be made, and another payee may have priority over IRS.