A law firm partner’s advances on partnership profits are subject to administrative levies imposed by the Internal Revenue Service, the 2nd U.S. Circuit Court of Appeals ruled Thursday.

The circuit found that the advances, or partner “draws,” at personal injury firm Moskowitz, Passman & Edelman constituted “salary or wages” under §6331(e) of the Internal Revenue Code. The firm will now have to pay the government nearly $1.5 million.