No. 24-416October Term 2024Decided Jun 12, 2025
Commissioner of Internal Revenue, Petitioner v. Jennifer Zuch
The Supreme Court held that a Tax Court proceeding challenging an IRS levy becomes moot and must be dismissed if the IRS abandons the proposed levy, meaning taxpayers must pursue any remaining disputes about tax liability through a separate refund suit.
Case status
- Current stage
- Decided
- Latest event
- Decision released Jun 12, 2025
- What it's about
The Supreme Court held that a Tax Court proceeding challenging an IRS levy becomes moot and must be dismissed if the IRS abandons the proposed levy, meaning taxpayers must pursue any remaining disputes about tax liability through a separate refund suit.
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?
- Case path
United States Court of Appeals for the Third Circuit / Decision released Jun 12, 2025
- Area
Decided Supreme Court case
Timing
Decided June 12, 2025
The Court released its decision 51 days after oral argument on April 22, 2025. The median for cases argued in April is 58 days.
Documents
Related cases
Grounding
- Grounding
- Primary-source trail available.
- Note
- Plain-English explainer. Official filings and opinions remain authoritative.
- Checked
- Mar 30, 2026
- Method
- Methodology
Primary materials8
Supreme Court docket 24-416
docket | Mar 30, 2026
Primary case document
Supreme Court document | Mar 30, 2026
CourtListener docket record
docket | Mar 30, 2026
Questions Presented
brief | Mar 8, 2026
opinion
opinion | Jun 12, 2025
Zuch
opinion | Jun 12, 2025
Oral Arguments - Zuch
audio | Apr 22, 2025
Petition
brief | Oct 11, 2024