In his latest article by Law360, "Drawbacks for Taxpayers From Justices' Levy Dispute Ruling," firm partner Matthew L. Roberts analyzes the Supreme Court's recent decision in Commissioner v. Zuch, a decision which sharply limits taxpayers from challenging their liabilities or seeking refunds in a Collection Due Process (CDP) hearing after the liabilities are satisfied. In allowing the IRS to remove a taxpayer’s case from Tax Court jurisdiction through administrative offsets, the ruling highlights the critical need for taxpayers to carefully monitor their CDP hearing liabilities and navigate strict refund claim deadlines.