20% withholding on plan distribution to satisfy IRS tax levy?

[Wessex]

Does the 20% withholding requirement for "eligible rollover distributions" apply to amounts distributed to the IRS to satisfy a tax levy on a participant's account? A citation to the applicable authority (if there is any) would be much appreciated. Thanks.

[Guest gpr]

What is/was the basis of the distribution? In other words, is/was it considered a hardship withdrawal (for example) in accordance with the plan document? You may be aware that the 'loophole' for rolling over hardship withdrawals has been closed - no longer eligible for rollover, no longer 20% mandatory withholding.

[Wessex]

It is a payment directly to the IRS pursuant to a tax levy; it is not a payment to the participant under an in-service hardship or othre distribution provision.