Hinck v. United States, 550 U.S. 501 (2007)
Primary Holding
The Tax Court provides the exclusive forum for judicial review of a refusal to abate interest under §6404(e)(1) of the Internal Revenue Code.
In the case of Hinck v. United States, the Supreme Court decided that if you want to challenge the IRS's decision not to forgive interest on unpaid taxes due to their mistakes or delays, you must do so in the Tax Court and not in other courts. This is important because it clarifies where consumers can go for help if they feel the IRS has unfairly charged them interest. If you find yourself in a situation where you believe the IRS has made an error that affects your tax interest, this ruling tells you the Tax Court is the place to seek a resolution.
AI-generated plain-language summary to help you understand this case
In Hinck v. United States, the underlying dispute arose from the failure of John F. Hinck and his wife to pay federal income taxes on time, resulting in the accrual of interest on the unpaid amount. The Internal Revenue Service (IRS) later determined that the Hincks owed taxes, and they sought relief from the interest accrued due to what they claimed was unreasonable error or delay by the IRS in processing their tax affairs. Under Section 6404(e)(1) of the Internal Revenue Code, the Secretary of the Treasury has the authority to abate interest in such cases, and the Hincks sought to challenge the Secretary's decision not to grant this relief. The case reached the Supreme Court on a writ of certiorari after the Federal Circuit Court of Appeals ruled on the issue of whether judicial review of the Secretary's decision regarding interest abatement could be pursued only in the Tax Court or in other courts, such as district courts and the Court of Federal Claims. The Supreme Court was tasked with clarifying the appropriate forum for such judicial review, given the conflicting interpretations that had emerged in lower courts regarding the scope of Section 6404(h) and its implications for taxpayer rights. The relevant background context includes the legislative history of Section 6404, which was amended multiple times, notably in the Tax Reform Act of 1986 and the Taxpayer Bill of Rights 2 in 1996. These amendments aimed to provide taxpayers with certain protections and clarify the circumstances under which interest could be abated. Prior to the amendments, federal courts had generally held that the Secretary's decisions regarding interest abatement were not subject to judicial review, as they were deemed committed to agency discretion. The Supreme Court's decision ultimately affirmed that the Tax Court is the exclusive forum for such challenges, thereby reinforcing the established interpretation of the statute.
Whether judicial review of the Secretary of the Treasury's decision not to grant abatement of interest under §6404(e)(1) of the Internal Revenue Code is exclusively available in the Tax Court, or if it can also be sought in district courts and the Court of Federal Claims.
The judgment of the United States Court of Appeals for the Federal Circuit is affirmed.
- Court
- Supreme Court
- Decision Date
- April 23, 2007
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Roberts
- Damages Awarded
- N/A
- Data Quality
- high
EC Term of Years Trust v. United States, 550 U.S. 429 (2007)
Consumer LostA trust cannot challenge an IRS levy on its property through a tax refund action if it has missed the statutory filing deadline for contesting the levy under 26 U.S.C. §7426(a)(1).
Ballard v. Commissioner, 544 U.S. 40 (2005)
Consumer LostThe Supreme Court held that the Tax Court's practice of withholding special trial judges' reports from the public and excluding them from the record on appeal violates the principles of due process and transparency in judicial proceedings.
Will v. Hallock, 546 U.S. 345 (2006)
Consumer LostThe refusal to apply the judgment bar of the Federal Tort Claims Act is not subject to collateral appeal, as it does not constitute a final decision under 28 U.S.C. §1291.
Department of Revenue of Ky. v. Davis, 553 U.S. 328 (2008)
Consumer LostKentucky's differential tax scheme, which exempts interest on bonds issued by the state and its political subdivisions while taxing interest on bonds from other states, does not violate the Commerce Clause of the United States Constitution.