Supreme Court of the United States · Official docket →
Commissioner of Internal Revenue v. Jennifer Zuch
Paid petition · United States Court of Appeals for the Third Circuit, No. 22-2244 · judgment March 22, 2024
Before the decision, about 6.4× the 4.1% base rate. The model weighted this up for a federal-government petitioner, counsel who has won certiorari before, and a Third Circuit decision below.
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.
Counsel of record
For petitioner
Brian Halligan Fletcher
Department of Justice
For respondent
Shay Dvoretzky
Skadden, Arps, Slate, Meagher & Flom LLP
Case
Conference history
Distributed for 1 conference
Amicus briefs
4 merits
(4 respondent)
Argument & decision
Argued April 22, 2025 — Erica L. Ross · Shay Dvoretzky. Audio and transcript
Decided June 12, 2025. Opinion by Barrett.
Proceedings
- Aug 05 2025Record returned to the United States Court of Appeals for the Third Circuit.
- Jul 14 2025Judgment Issued.
- Jun 12 2025Judgment REVERSED and case REMANDED. Barrett, J., delivered the opinion of the Court, in which Roberts, C. J., and Thomas, Alito, Sotomayor, Kagan, Kavanaugh, and Jackson, JJ., joined. Gorsuch, J., filed a dissenting opinion.
- Apr 22 2025Argued. For petitioner: Erica L. Ross, Assistant to the Solicitor General, Department of Justice, Washington, D. C. For respondent: Shay Dvoretzky, Washington, D. C.
- Apr 11 2025Reply of petitioner Commissioner of Internal Revenue filed. (Distributed)
- Mar 24 2025Brief amicus curiae of The Chamber of Commerce of the United States of America filed. (Distributed)
- Mar 24 2025Brief amicus curiae of A. Lavar Taylor filed. (Distributed)
- Mar 24 2025Brief amici curiae of National Taxpayers Union Foundation, et al. filed. (Distributed)
- Mar 24 2025Brief amicus curiae of Center for Taxpayer Rights filed. (Distributed)
- Mar 19 2025CIRCULATED
- Mar 17 2025Brief of respondent Jennifer Zuch filed.
- Mar 07 2025Record received from the United States Court of Appeals for the Third Circuit and available electronically with the Clerk.
- Feb 26 2025Record requested from the United States Court of Appeals for the Third Circuit.
- Feb 24 2025Motion to dispense with printing the joint appendix filed by petitioner GRANTED.
- Feb 24 2025SET FOR ARGUMENT on Tuesday, April 22, 2025.
- Feb 14 2025Brief of petitioner Commissioner of Internal Revenue filed.
- Feb 06 2025Motion to dispense with printing the joint appendix filed by petitioner Commissioner of Internal Revenue.
- Jan 10 2025Petition GRANTED.
- Dec 24 2024DISTRIBUTED for Conference of 1/10/2025.
- Dec 23 2024Reply of petitioner Commissioner of Internal Revenue filed. (Distributed)
- Dec 19 2024Waiver of the 14-day waiting period for the distribution of the petition pursuant to Rule 15.5 filed by petitioners.
- Dec 16 2024Brief of respondent Jennifer Zuch in opposition filed.
- Oct 17 2024Motion to extend the time to file a response is granted and the time is extended to and including December 16, 2024.
- Oct 15 2024Motion to extend the time to file a response from November 14, 2024 to December 16, 2024, submitted to The Clerk.
- Oct 11 2024Petition for a writ of certiorari filed. (Response due November 14, 2024)
- Sep 12 2024Application (24A256) granted by Justice Alito extending the time to file until October 11, 2024.
- Sep 11 2024Application (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.