Third Circuit rules taxpayer's claim is not moot.

The article focuses on the Third Circuit's decision that a taxpayer's claim regarding the allocation of prepayments was not moot, reversing the Tax Court's dismissal of the case. Topics include the invalidation of the Internal Revenue Service's (IRS) setoffs of tax prepayments, the jurisdiction of the Tax Court in reviewing such setoffs; and the broader implications for taxpayer rights in Collection Due Process (CDP) hearings.