Carol Gray v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that the exhaustion requirement under 26 U.S.C. § 7433(d) is a prerequisite to filing a refund suit in district court
• describing exhaustion as “a condition on the government’s waiver of sovereign immunity” and as an “affirmative defense”
• describing exhaustion as “a condition on the government’s waiver of sovereign immunity” and as an “affirmative defense”
• discussing the difference between exhaustion requirements that are jurisdictional and those that are not
• affirming legality of regulations requiring exhaustion before plaintiff can file suit
• “Although a plaintiff must exhaust administrative remedies to recover damages under § 7433, exhaustion is not a jurisdictional requirement.”

Source: CourtListener parenthetical corpus (CC0).