Commissioner v. Zuch
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Commissioner v. Zuch and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Commissioner v. Zuch.
The Supreme Court addressed the jurisdiction of the Tax Court in cases where the IRS is no longer pursuing a levy. The Court determined that the Tax Court lacks jurisdiction to resolve disputes once the IRS has abandoned the levy. The decision emphasizes the limited scope of the Tax Court's authority under § 6330.
Holding
The single most important “bottom line” of what the Court decided in Commissioner v. Zuch.
The Court held that the Tax Court lacks jurisdiction under § 6330 to resolve disputes between a taxpayer and the IRS when the IRS is no longer pursuing a levy.
Constitutional Concepts
These are the Constitution-related themes that appear in Commissioner v. Zuch. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Commissioner v. Zuch
The case involves the procedural rights of a taxpayer in the context of IRS levy actions and the jurisdiction of the Tax Court to review such actions.
Syllabus excerpt (verbatim)The Tax Court lacks jurisdiction under § 6330 to resolve disputes between a taxpayer and the IRS when the IRS is no longer pursuing a levy.
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Why Remedies and Relief is relevant to Commissioner v. Zuch
The decision discusses the limits on the Tax Court's authority to provide relief beyond enjoining a levy, such as ordering refunds or issuing declaratory judgments.
Syllabus excerpt (verbatim)Finally, the Court doubts the Tax Court has authority under § 6330(e) to provide relief beyond enjoining a levy.
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Why Standing is relevant to Commissioner v. Zuch
The case addresses whether there is a justiciable controversy for the Tax Court to resolve once the IRS is no longer pursuing a levy.
Syllabus excerpt (verbatim)The IRS moved to dismiss the Tax Court proceeding as moot, arguing that the Tax Court lacked jurisdiction because the IRS no longer had a basis to levy on Zuch's property.
Key Quotes
Short excerpts from the syllabus in Commissioner v. Zuch that support the summary and concepts above.
The Tax Court is a court of limited jurisdiction.
The Tax Court lacked jurisdiction to opine on disputed tax liability independent of any ongoing collection effort.
The IRS's abandonment of the levy did not moot the Tax Court proceedings.
