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UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
_______________
No. 22-2244
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JENNIFER ZUCH,
Appellant
v.
COMMISSIONER OF INTERNAL REVENUE
_______________
On Appeal from the United States Tax Court
(IRS 1:14-25125)
Tax Court Judge: Honorable Lewis R. Carluzzo
_______________
Argued April 26, 2023
Submitted on Remand from the Supreme Court of the United States
on July 14, 2025
Before: KRAUSE and BIBAS*, Circuit Judges
JUDGMENT ORDER
In accordance with the mandate of the Supreme Court of the United States issued
July 14, 2025, it is ORDERED and ADJUDGED the order of the Tax Court entered on
April 6, 2022 is hereby AFFIRMED. The Clerk is directed to issue the mandate
forthwith.
* The Honorable Kent A. Jordan was a member of the merits panel. Judge Jordan retired
from the Court on January 15, 2025 and did not participate in the consideration of this
matter on remand. This order is issued filed by a quorum of the Court. 28 U.S.C. § 46
and Third Circuit IOP 12.1.
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BY THE COURT,
s/ Cheryl Ann Krause
Circuit Judge
ATTEST:
s/Patricia S. Dodszuweit
Clerk
DATE: July 16, 2025
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