In an article published in Bloomberg Tax on January 31, 2025, Shareholder Jasen Hanson discusses the Commissioner v. Zuch Supreme Court case and how it may potentially impact taxpayers and tax practitioners.
“A pro-taxpayer ruling would uphold the Tax Court’s jurisdiction over underlying liability disputes. It would uphold the current view that the Tax Court has jurisdiction over cases to review of due process hearing determinations involving IRS collection activities. Taxpayers will maintain their right to prepayment challenges of the IRS’s collection efforts,” Hanson wrote.
Hanson explained, “If the Supreme Court narrows the Tax Court’s jurisdiction, it would affect numerous tax practitioners and taxpayers facing federal tax disputes. Without the prepayment venue of the Tax Court, taxpayers would be forced to pay the full amount of taxes and/or penalties asserted against them before they could sue for a refund.”
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