Justices Urged to Skip IRS Challenge to Tax Court Jurisdiction

The US Supreme Court should deny the IRS’s petition challenging whether the US Tax Court has jurisdiction over a levy redetermination suit once the agency stops pursuing the levy, a taxpayer said Monday.

The IRS warned the high court in October that a ruling by the US Court of Appeals for the Third Circuit “could be used to transform the nature of a Section 6330 proceeding,” expanding the Tax Court’s jurisdiction far beyond the pre-levy proceedings intended by Congress. Taxpayer Jennifer Zuch urged the justices to deny the agency’s petition, arguing the outcome created no circuit split despite the agency’s ...