Questions 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.
Case Updates
U.S. Chamber files amicus brief urging Supreme Court to hold that IRS cannot deprive Tax Court of jurisdiction over Collection Due Process proceedings by crediting subsequent overpayments to a taxpayer's contested debt
March 24, 2025
The Chamber's amicus brief emphasizes the hardship the IRS' position could impose on small business.
Lauren Willard Zehmer, Kandyce Jayasinghe, and Emily Caputo of Covington & Burling LLP served as outside counsel.