UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _______________ No. 22-2244 _______________ 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.

BY THE COURT, s/ Cheryl Ann Krause Circuit Judge ATTEST: s/Patricia S. Dodszuweit Clerk DATE: July 16, 2025