Supreme Court’s Newest Tax Case Offers Window to Challenge IRS

Jan. 15, 2025, 7:39 PM UTC

The US Supreme Court’s decision to take up a case on the US Tax Court’s authority provides an opportunity for the justices to rule broadly on a due process issue of particular importance to low-income taxpayers, legal observers said.

Commissioner v. Zuch concerns whether a Tax Court challenge to a levy became moot once the IRS stopped pursuing that levy while the litigation was pending.

On its face, the case is a “ticky-tacky procedural issue,” said Adam Chodorow, a professor at Arizona State University’s Sandra Day O’Connor College of Law.

He and other legal observers said they were surprised ...

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