A Notebook LM generated review of a June 2025 United States Supreme Court opinion and accompanying dissenting opinion address Commissioner of Internal Revenue v. Zuch, a case concerning the jurisdiction of the United States Tax Court. The majority opinion holds that the Tax Court's authority to review a Collection Due Process (CDP) hearing ends once a proposed levy by the IRS is abandoned, even if the taxpayer still disputes the underlying tax liability. This is because the Tax Court's jurisdiction under §6330 is limited to reviewing the IRS's "determination" regarding the appropriateness of a levy. The dissenting opinion argues that this interpretation improperly restricts the Tax Court's jurisdiction, contending that its review should extend to all issues resolved in the initial "determination," including the underlying tax liability, regardless of whether a levy remains active. The dissent warns that the majority's decision grants the IRS an unjust advantage, allowing it to circumvent judicial review by dropping a levy when a ruling appears unfavorable to the agency.