Opinion Summary: Commissioner of Internal Revenue v. Zuch | Date Decided: 6/12/25 | Case No. 24–416

Link to Docket: Here.

Question 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.

Holding: The Tax Court lacks jurisdiction under Section 6330 to resolve disputes between a taxpayer and the IRS when the IRS is no longer pursuing a levy.

Result: Reversed and remanded.

Voting Breakdown: 8-1. Justice Barrett delivered the opinion of the Court, in which Chief Justice Roberts and Justices Thomas, Alito, Sotomayor, Kagan, Kavanaugh and Jackson joined. Justice Gorsuch filed a dissenting opinion.

Link to Opinion: Here.

Oral Advocates:

• For petitioner: Erica L. Ross, Assistant to the Solicitor General, Department of Justice, Washington, D.C.
• For respondent: Shay Dvoretzky, Washington, D.C.

Apple Podcast Link to Oral Argument: Here.