Record returned to the United States Court of Appeals for the Third Circuit.

Judgment Issued.

Judgment REVERSED and case REMANDED. Barrett, J., delivered the <a href = 'https://www.supremecourt.gov/opinions/24pdf/24-416_l5gm.pdf'>opinion</a> of the Court, in which Roberts, C. J., and Thomas, Alito, Sotomayor, Kagan, Kavanaugh, and Jackson, JJ., joined. Gorsuch, J., filed a dissenting opinion.

Argued. For petitioner: Erica L. Ross, Assistant to the Solicitor General, Department of Justice, Washington, D. C. For respondent: Shay Dvoretzky, Washington, D. C.

Reply of petitioner Commissioner of Internal Revenue filed. (Distributed)

Brief amicus curiae of Center for Taxpayer Rights filed. (Distributed)

Brief amici curiae of National Taxpayers Union Foundation, et al. filed. (Distributed)

Brief amicus curiae of A. Lavar Taylor filed. (Distributed)

Brief amicus curiae of The Chamber of Commerce of the United States of America filed. (Distributed)

CIRCULATED

Brief of respondent Jennifer Zuch filed.

Record received from the United States Court of Appeals for the Third Circuit and available electronically with the Clerk.

Record requested from the United States Court of Appeals for the Third Circuit.

SET FOR ARGUMENT on Tuesday, April 22, 2025.

Motion to dispense with printing the joint appendix filed by petitioner GRANTED.

Brief of petitioner Commissioner of Internal Revenue filed.

Motion to dispense with printing the joint appendix filed by petitioner Commissioner of Internal Revenue.

Petition GRANTED.

DISTRIBUTED for Conference of 1/10/2025.

Reply of petitioner Commissioner of Internal Revenue filed. (Distributed)

Waiver of the 14-day waiting period for the distribution of the petition pursuant to Rule 15.5 filed by petitioners.

Brief of respondent Jennifer Zuch in opposition filed.

Motion to extend the time to file a response is granted and the time is extended to and including December 16, 2024.

Motion to extend the time to file a response from November 14, 2024 to December 16, 2024, submitted to The Clerk.

Petition for a writ of certiorari filed. (Response due November 14, 2024)

Application (24A256) granted by Justice Alito extending the time to file until October 11, 2024.

Application (24A256) to extend the time to file a petition for a writ of certiorari from September 24, 2024 to October 11, 2024, submitted to Justice Alito.

Commissioner of Internal Revenue, Petitioner, represented by D. John Sauer

United States, Petitioner, represented by Brian Halligan Fletcher

Jennifer Zuch, Respondent, represented by Shay Dvoretzky

A. Lavar Taylor, Amicus Curiae, represented by A. Lavar Taylor

National Taxpayers Union Foundation, Amicus Curiae, represented by Joseph Darcy Henchman

The Center for Taxpayer Rights, Amicus Curiae, represented by Audrey Anne Patten

The Chamber of Commerce of the United States of America, Amicus Curiae, represented by Lauren Willard Zehmer