Plain-English summary
Court rules challenges to IRS levy proceedings are not automatically moot when the specific proposed levy ends
The Court held that a taxpayer’s appeal of an IRS pre-deprivation hearing under 26 U.S.C. § 6330 does not automatically become moot just because the IRS no longer intends to use the exact levy that prompted the challenge. The decision reverses the Third Circuit and sends the case back for further consideration under the proper standards.
Why this matters
The ruling limits the government's ability to avoid judicial review of IRS collection procedures by dropping or modifying a specific levy once a taxpayer seeks review. That preserves taxpayers’ access to pre-deprivation process in meaningful cases and affects how courts treat similar tax-collection and administrative-law disputes about mootness.
Who may feel it
- Individual taxpayers facing IRS levies or collection actions
- Tax practitioners and tax-exempt organizations advising clients on administrative appeals
- The IRS and other government agencies that use enforcement tools
- Federal courts deciding when enforcement-related cases become moot
Key questions
- Does a Section 6330 pre-deprivation proceeding challenging a proposed IRS levy become moot when the IRS no longer pursues the same levy?