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ZUCH v. COMMISSIONER OF INTERNAL REVENUE

No. 22-2244.

JENNIFER ZUCH, Appellant, v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals, Third Circuit.

Filed: March 22, 2024.

Attorney(s) appearing for the Case

Frank Agostino , Agostino & Associates, 14 Washington Place Hackensack, NJ 07601.

Jeffrey M. Dirmann [ARGUED], 4th Floor, Suite 17, 55 Madison Avenue, Morristown, NJ 07960, Counsel for Appellant.

Julie C. Avetta [ARGUED], Jennifer M. Rubin , United States Department of Justice, Tax Division, 950 Pennsylvania Avenue NW, P.O. Box 502, Washington, DC 20044, Counsel for Appellee.

Audrey Patten, Legal Services Center of Harvard Law School, 122 Boylston Street, Jamaica Plain, MA 02130, Court-Appointed Amicus Curiae.*

Before: JORDAN, KRAUSE, and BIBAS*,

OPINION OF THE COURT1

When Congress grants taxpayers the right to challenge what the Internal Revenue Service says is owed to the government, Congress's will prevails. The IRS cannot say that such a right exists only under the circumstances it prescribes. That ought to go without...

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