Case: Tax Court Lacked Jurisdiction After IRS Abandoned Levy; Supreme Court Reverses Decision of 3d. Cir. (U.S.) (IRC §6330)

The Tax Court lacks jurisdiction to resolve disputes between a taxpayer and the IRS when the IRS is no longer pursuing a levy, the U.S. Supreme Court held, reversing and remanding the decision of the U.S. Court of Appeals for the Third Circuit. Taxpayer, an individual, filed an untimely 2010 tax return reporting no outstanding tax obligations. Taxpayer’s then-husband separately filed a return reflecting a substantial balance due, and the IRS applied estimated tax payments the couple had previously made to the husband’s account. Taxpayer later filed an amended 2010 return reporting additional income and tax liability, but claimed the ...