Hinck v. United States (2006)
- Docket
- 06-376
- Decided
- 2006-01-01
Summary
Question: Does Section 6404(h) of the Internal Revenue Code grant the United States Tax Court exclusive jurisdiction to review interest abatement claims made against the Internal Revenue Service? Conclusion: Yes. Chief Justice John G. Roberts Jr. wrote for a unanimous court that Section 6404(e)(1) requires that claims challenging a refusal to abate (i.e. forgive) interest be brought exclusively in Tax Court. The Court reasoned that its ruling was consistent with the principle that when Congress enacts a detailed, specific judicial remedy (such as 6404(e)(1)) where there was no remedy before, the new remedy will be regarded as exclusive. The Court insisted on reading the statute as a unified whole, so that all of the procedures outlined by Congress for interest abatement claims applied exclusively to the forum (U.S. Tax Court) that Congress mentioned in the same statute. To do otherwise would be to "disaggregat[e] a statute Congress plainly envisioned as a package deal."