Commissioner of Internal Revenue v. Zuch
| Docket No. | Op. Below | Argument | Opinion | Vote | Author | Term |
|---|---|---|---|---|---|---|
| 24-416 | 3rd Cir. | Apr 22, 2025 | Jun 12, 2025 | 8-1 | Barrett | OT 2024 |
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 Justice Barrett on June 12, 2025. Justice Gorsuch filed a dissenting opinion.
SCOTUSblog Coverage
- Additional opinions from Thursday, June 12 (SCOTUSblog, June 12, 2025)
- April session to feature religious charter school case and challenge to LGBTQ+ books in schools (Amy Howe, February 24, 2025)
- Court adds three new cases (Amy Howe, January 11, 2025)
- Justices meet to fill out 2024-25 docket (Kalvis Golde, January 10, 2025)
| Date | Proceedings and Orders |
|---|---|
| 09/11/2024 | 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. |
| 09/12/2024 | Application (24A256) granted by Justice Alito extending the time to file until October 11, 2024. |
| 10/11/2024 | Petition for a writ of certiorari filed. (Response due November 14, 2024) |
| 10/15/2024 | Motion to extend the time to file a response from November 14, 2024 to December 16, 2024, submitted to The Clerk. |
| 10/17/2024 | Motion to extend the time to file a response is granted and the time is extended to and including December 16, 2024. |
| 12/16/2024 | Brief of respondent Jennifer Zuch in opposition filed. |
| 12/19/2024 | Waiver of the 14-day waiting period for the distribution of the petition pursuant to Rule 15.5 filed by petitioners. |
| 12/23/2024 | Reply of petitioner Commissioner of Internal Revenue filed. (Distributed) |
| 12/24/2024 | DISTRIBUTED for Conference of 1/10/2025. |
| 01/10/2025 | Petition GRANTED. |
| 02/06/2025 | Motion to dispense with printing the joint appendix filed by petitioner Commissioner of Internal Revenue. |
| 02/14/2025 | Brief of petitioner Commissioner of Internal Revenue filed. |
| 02/24/2025 | Motion to dispense with printing the joint appendix filed by petitioner GRANTED. |
| 02/24/2025 | SET FOR ARGUMENT on Tuesday, April 22, 2025. |
| 02/26/2025 | Record requested from the United States Court of Appeals for the Third Circuit. |
| 03/07/2025 | Record received from the United States Court of Appeals for the Third Circuit and available electronically with the Clerk. |
| 03/17/2025 | Brief of respondent Jennifer Zuch filed. |
| 03/19/2025 | CIRCULATED |
| 03/24/2025 | Brief amicus curiae of The Chamber of Commerce of the United States of America filed. (Distributed) |
| 03/24/2025 | Brief amicus curiae of A. Lavar Taylor filed. (Distributed) |
| 03/24/2025 | Brief amici curiae of National Taxpayers Union Foundation, et al. filed. (Distributed) |
| 03/24/2025 | Brief amicus curiae of Center for Taxpayer Rights filed. (Distributed) |
| 04/11/2025 | Reply of petitioner Commissioner of Internal Revenue filed. (Distributed) |
| 04/22/2025 | Argued. For petitioner: Erica L. Ross, Assistant to the Solicitor General, Department of Justice, Washington, D. C. For respondent: Shay Dvoretzky, Washington, D. C. |
| 06/12/2025 | 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. |