On June 25, 2020, the Tax Court issued its opinion in Ruesch v. Commissioner (154 T.C. No. 13). The two issues in Ruesch v. Commissioner were (1) whether the Tax Court possessed jurisdiction under IRC § 7345(b) to consider the petitioner’s challenge to her underlying tax debts; and (2) whether the Tax Court possessed jurisdiction to review the petitioner’s challenge to the IRS’s certification of the petitioner’s liabilities as “seriously delinquent pursuant to IRC §