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Commissioner of Internal Revenue v. Zuch

Docket No.24-416
Op. Below3rd Cir.
ArgumentApr 22, 2025

Holding

The United States Tax Court lacks jurisdiction under 26 U.S.C. § 6330 to resolve disputes between a taxpayer and the Internal Revenue Service when the IRS is no longer pursuing a levy.

Judgment

Reversed and remanded, 8-1, in an opinion by Amy Coney Barrett on Jun 12, 2025. Justice Gorsuch filed a dissenting opinion.

Proceedings & orders timeline

Sep 11, 2024
Application (24A256) to extend the time to file a petition for a writ of certiorari from September 24, 2024 to October 11, 2024, submitted to Justice Alito.
Sep 12, 2024
Application (24A256) granted by Justice Alito extending the time to file until October 11, 2024.
Oct 11, 2024
Petition for a writ of certiorari filed. (Response due November 14, 2024)
Oct 15, 2024
Motion to extend the time to file a response from November 14, 2024 to December 16, 2024, submitted to The Clerk.
Oct 17, 2024
Motion to extend the time to file a response is granted and the time is extended to and including December 16, 2024.
Dec 16, 2024
Brief of respondent Jennifer Zuch in opposition filed.
Dec 19, 2024
Waiver of the 14-day waiting period for the distribution of the petition pursuant to Rule 15.5 filed by petitioners.
Dec 23, 2024
Reply of petitioner Commissioner of Internal Revenue filed. (Distributed)
Dec 24, 2024
DISTRIBUTED for Conference of 1/10/2025.
Jan 10, 2025
Petition GRANTED.
Feb 6, 2025
Motion to dispense with printing the joint appendix filed by petitioner Commissioner of Internal Revenue.
Feb 14, 2025
Brief of petitioner Commissioner of Internal Revenue filed.
Feb 24, 2025
Motion to dispense with printing the joint appendix filed by petitioner GRANTED.
Feb 24, 2025
SET FOR ARGUMENT on Tuesday, April 22, 2025.
Feb 26, 2025
Record requested from the United States Court of Appeals for the Third Circuit.
Mar 7, 2025
Record received from the United States Court of Appeals for the Third Circuit and available electronically with the Clerk.
Mar 17, 2025
Brief of respondent Jennifer Zuch filed.
Mar 19, 2025
CIRCULATED
Mar 24, 2025
Brief amicus curiae of The Chamber of Commerce of the United States of America filed. (Distributed)
Mar 24, 2025
Brief amicus curiae of A. Lavar Taylor filed. (Distributed)
Mar 24, 2025
Brief amici curiae of National Taxpayers Union Foundation, et al. filed. (Distributed)
Mar 24, 2025
Brief amicus curiae of Center for Taxpayer Rights filed. (Distributed)
Apr 11, 2025
Reply of petitioner Commissioner of Internal Revenue filed. (Distributed)
Apr 22, 2025
Argued. For petitioner: Erica L. Ross, Assistant to the Solicitor General, Department of Justice, Washington, D. C. For respondent: Shay Dvoretzky, Washington, D. C.
Jun 12, 2025
Judgment REVERSED and case REMANDED. Barrett, J., delivered the opinion of the Court, in which Roberts, C. J., and Thomas, Alito, Sotomayor, Kagan, Kavanaugh, and Jackson, JJ., joined. Gorsuch, J., filed a dissenting opinion.
Jul 14, 2025
Judgment Issued.
Aug 5, 2025
Record returned to the United States Court of Appeals for the Third Circuit.

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