Questions Presented
Whether a proceeding under 26 U.S.C. 6330 for a pre-deprivation determination about a levy proposed by the Internal Revenue Service to collect unpaid taxes becomes moot when there is no longer a live dispute over the proposed levy that gave rise to the proceeding.
Case Updates
Divided Supreme Court holds that Tax Court is divested of jurisdiction over a Collection Due Process suit when the IRS credits subsequent overpayments to a taxpayer's contested debt
June 12, 2025
U.S. Chamber files amicus brief urging Supreme Court to hold that IRS cannot deprive Tax Court of jurisdiction over Collection Due Process proceedings by crediting subsequent overpayments to a taxpayer's contested debt
March 24, 2025
The Chamber's amicus brief emphasizes the hardship the IRS' position could impose on small business.
Lauren Willard Zehmer, Kandyce Jayasinghe, and Emily Caputo of Covington & Burling LLP served as outside counsel.
Case Documents
- U.S. Chamber Amicus Brief -- Commissioner of Internal Revenue v. Zuch (U.S. Supreme Court)
- Opinion -- Commissioner of Internal Revenue v. Zuch (U.S. Supreme Court)