12 June 2025 US Supreme Court finds US Tax Court lacked jurisdiction to hear challenge to satisfied levy The US Supreme Court has ruled that the US Tax Court lacked jurisdiction to continue proceedings in a collections due process case once the IRS abandoned a levy that had been satisfied by applying a taxpayer's refunds to the amount owed. In Commissioner v. Zuch, No. 24-416 (June 12, 2025), the Supreme Court held 8-1 that once the IRS applied the overpayments to the taxpayer's debt, the basis for the levy no longer existed and the Tax Court lacked a "determination" to review under IRC Section 6330. A Tax Alert is forthcoming.
Document ID: 2025-1239 | ||
