Commissioner of Internal Revenue v. Zuch
U.S. Supreme Court · decided June 12, 2025 · Supreme Court Database (Spaeth)
- Decided
- June 12, 2025
- Term
- October Term 2024
- Vote
- 8–1
- Majority author
- Justice Barrett
- Issue area
- Federal Taxation
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
PRELIMINARY PRINT Volume 605 U. S. Part 2 Pages 422–442 OFFICIAL REPORTS OF THE SUPREME COURT June 12, 2025 Page Proof Pending Publication REBECCA A. WOMELDORF reporter of decisions NOTICE: This preliminary print is subject to formal revision before the bound volume is published. Users are requested to notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, pio@supremecourt.gov, of any typographical or other formal errors. Syllabus COMMISSIONER OF INTERNAL REVENUE v. ZUCH certiorari to the united states court of appeals for the third circuit No. 24–416. Argued April 22, 2025—Decided June 12, 2025 This case involves the jurisdiction of the United States Tax Court over appeals from collection due process hearings when there is no longer an ongoing levy. The dispute here began in 2012, when Jennifer Zuch and her then-husband Patrick Gennardo each fled an untimely 2010 federal tax return. Gennardo subsequently submitted an offer in compromise to resolve outstanding tax liabilities. This offer implicated $50,000 in estimated tax payments that the couple had previously sent to the IRS; following the offer, the IRS applied these payments to Gennardo's ac- count. For her part, Zuch later amended her 2010 tax return to report additional income, which resulted in an additional $28,000 in taxes due. But Zuch maintained that the IRS should have…
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