At the heart of this decision is when the Tax Court can step in. Under federal law, the Tax Court can only review an IRS determination about whether it may seize assets to cover unpaid taxes — a process called a levy. In Commissioner v. Zuch, the IRS stopped its levy because the taxpayer’s debt was wiped out by earlier overpayments. This structure ensures that collection due process hearings remain focused on their intended purpose—providing taxpayers with procedural protections before the IRS seizes their property—rather than becoming an alternative route to challenge tax assessments more broadly.

music for the podcast provided by ⁠⁠⁠⁠ Dimitry Taras