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Due Process › Supreme Court of the United States › Tax Court

Lippes Mathias LLP

Supreme Court Undermines Taxpayers’ Due Process Rights

Lippes Mathias LLP on

On June 12, 2025, the U.S. Supreme Court issued a significant decision in Commissioner of Internal Revenue v. Zuch, clarifying the jurisdictional boundaries of the U.S. Tax Court in Collection Due Process (CDP) appeals....more

Hone Maxwell

Supreme Court Gives IRS Ability to Levy Taxpayers Without Tax Court Challenge

Hone Maxwell on

In a pivotal ruling, the U.S. Supreme Court on June 12, 2025, held that the U.S. Tax Court lacks jurisdiction to hear a taxpayer’s Collection Due Process appeal under IRC § 6330 once the IRS can no longer pursue a levy,...more

Dorsey & Whitney LLP

The Supreme Court Update - June 12, 2025

Dorsey & Whitney LLP on

The Supreme Court of the United States issued six decisions today: Parrish v. United States, No. 24-275: This case addresses the procedural requirements for filing a notice of appeal after the original deadline to appeal...more

Rivkin Radler LLP

Challenge to Collection Due Process? Will Supreme Court Affirm IRS’s Offset of Valid Refund With Disputed Tax Liability?

Rivkin Radler LLP on

Earlier this year the IRS announced that, as part of its larger compliance efforts begun last fall under the Inflation Reduction Act, the agency’s stepped-up enforcement activity with respect to high wealth, high income...more

Miller Canfield

Procedural Actions Following the Supreme Court Remand in Boechler

Miller Canfield on

Key Takeaways: ..In Boechler P.C., v. Commissioner (“Boechler”), the Supreme Court held that the thirty-day period to petition the Tax Court for review of an adverse determination by the IRS Appeals Office in a collection...more

McDermott Will & Emery

Late CDP Petitions May Still Be Entitled to Tax Court Review

McDermott Will & Emery on

In a unanimous decision in Boechler, P.C. v. Commissioner issued on April 21, 2022, the Supreme Court of the United States reversed the US Court of Appeals for the Eighth Circuit’s ruling (which affirmed the US Tax Court) and...more

Freeman Law

Supreme Court Update on Tax Cases (March 1, 2022)

Freeman Law on

Multiple federal tax cases continue to make their way to the U.S. Supreme Court, and it has certainly been interesting to monitor changes and updates to the Court’s docket. I previously wrote a blog on the oral arguments held...more

Freeman Law

CDP Proceedings—Is the Time Limit in Section 6330(d)(1) a Jurisdictional Requirement for Tax Court Petitions?

Freeman Law on

In the tax universe, deadlines are normal and expected. Most Americans are familiar with income tax filing deadlines (e.g., April 15th), and businesses are familiar with employment tax deadlines (e.g., January 15th)....more

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