No. 24-416
Commissioner of Internal Revenue v. Jennifer Zuch
Amici (4)
Experienced Counsel
Tags: administrative-review internal-revenue-service jurisdictional-challenge pre-deprivation-proceeding tax-court tax-levy
Key Terms:
AdministrativeLaw SocialSecurity DueProcess Securities JusticiabilityDoctri
AdministrativeLaw SocialSecurity DueProcess Securities JusticiabilityDoctri
Latest Conference:
2025-01-10
Question Presented (AI Summary)
Whether a pre-levy proceeding under 26 U.S.C. 6330 becomes moot when there is no longer a live dispute over the proposed levy
Question Presented (OCR Extract)
QUESTION PRESENTED Whether a proceeding under 26 U.S.C. 6330 for a pre-deprivation determination about a levy proposed by the Internal Revenue Service to collect unpaid taxes becomes moot when there is no longer a live dispute over the proposed levy that gave rise to the proceeding. (I)
Docket Entries
2025-08-05
Record returned to the United States Court of Appeals for the Third Circuit.
2025-07-14
Judgment Issued.
2025-06-12
Judgment REVERSED and case REMANDED. Barrett, J., delivered the <a href = 'https://www.supremecourt.gov/opinions/24pdf/24-416_l5gm.pdf'>opinion</a> of the Court, in which Roberts, C. J., and Thomas, Alito, Sotomayor, Kagan, Kavanaugh, and Jackson, JJ., joined. Gorsuch, J., filed a dissenting opinion.
2025-04-22
Argued. For petitioner: Erica L. Ross, Assistant to the Solicitor General, Department of Justice, Washington, D. C. For respondent: Shay Dvoretzky, Washington, D. C.
2025-04-11
Reply of petitioner Commissioner of Internal Revenue filed. (Distributed)
2025-03-24
Brief amicus curiae of The Chamber of Commerce of the United States of America filed. (Distributed)
2025-03-24
Amicus brief of The Chamber of Commerce of the United States of America submitted.
2025-03-24
Amicus brief of A. Lavar Taylor submitted.
2025-03-24
Amicus brief of The Center for Taxpayer Rights submitted.
2025-03-24
Brief amicus curiae of A. Lavar Taylor filed. (Distributed)
2025-03-24
Brief amici curiae of National Taxpayers Union Foundation, et al. filed. (Distributed)
2025-03-24
Brief amicus curiae of Center for Taxpayer Rights filed. (Distributed)
2025-03-19
CIRCULATED
2025-03-17
Brief of respondent Jennifer Zuch filed.
2025-03-07
Record received from the United States Court of Appeals for the Third Circuit and available electronically with the Clerk.
2025-02-26
Record requested from the United States Court of Appeals for the Third Circuit.
2025-02-24
SET FOR ARGUMENT on Tuesday, April 22, 2025.
2025-02-24
Motion to dispense with printing the joint appendix filed by petitioner GRANTED.
2025-02-14
Brief of petitioner Commissioner of Internal Revenue filed.
2025-02-14
Brief of Commissioner of Internal Revenue submitted.
2025-02-06
Motion to dispense with printing the joint appendix filed by petitioner Commissioner of Internal Revenue.
2025-02-06
Motion of Commissioner of Internal Revenue to dispense with joint appendix submitted.
2025-01-10
Petition GRANTED.
2024-12-24
DISTRIBUTED for Conference of 1/10/2025.
2024-12-23
Reply of petitioner Commissioner of Internal Revenue filed. (Distributed)
2024-12-23
Reply of petitioner United States filed. (Distributed)
2024-12-23
Reply of United States submitted.
2024-12-19
Waiver of the 14-day waiting period for the distribution of the petition pursuant to Rule 15.5 filed by petitioners.
2024-12-16
Brief of respondent Jennifer Zuch in opposition filed.
2024-12-16
Brief of Jennifer Zuch in opposition submitted.
2024-10-17
Motion to extend the time to file a response is granted and the time is extended to and including December 16, 2024.
2024-10-15
Motion to extend the time to file a response from November 14, 2024 to December 16, 2024, submitted to The Clerk.
2024-10-11
Petition for a writ of certiorari filed. (Response due November 14, 2024)
2024-09-12
Application (24A256) granted by Justice Alito extending the time to file until October 11, 2024.
2024-09-11
Application (24A256) to extend the time to file a petition for a writ of certiorari from September 24, 2024 to October 11, 2024, submitted to Justice Alito.
Attorneys
A. Lavar Taylor
A. Lavar Taylor — Taylor Nelson Amitrano LLP, Amicus
A. Lavar Taylor — Taylor Nelson Amitrano LLP, Amicus
Commissioner of Internal Revenue
D. John Sauer — Solicitor General, Petitioner
D. John Sauer — Solicitor General, Petitioner
Elizabeth B. Prelogar — Solicitor General, Petitioner
Sarah M. Harris — Acting Solicitor General, Petitioner
Jennifer Zuch
Shay Dvoretzky — Skadden, Arps, Slate, Meagher & Flom LLP, Respondent
Shay Dvoretzky — Skadden, Arps, Slate, Meagher & Flom LLP, Respondent
National Taxpayers Union Foundation
The Center for Taxpayer Rights
The Chamber of Commerce of the United States of America
Lauren Willard Zehmer — Covington & Burling LLP, Amicus
Lauren Willard Zehmer — Covington & Burling LLP, Amicus
United States
Brian Halligan Fletcher — Department of Justice, Petitioner
Brian Halligan Fletcher — Department of Justice, Petitioner