Hoogerheide v. Internal Revenue Service

How courts have described this case

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

• using the language of Section 7422 as an example of “how [the text of] an exhaustion requirement might establish a jurisdictional requirement”
• contrasting Sections 7422 and 7433 and noting that the language of the former establishes that exhaustion is jurisdictional, while the latter is merely “mandatory”
• considering 26 U.S.C. § 7433(d) (“A judgment for damages shall not be awarded . . . unless the court determines that the plaintiff has exhausted the administrative remedies.”)
• finding improperly addressed letters insufficient and rejecting as doubtful any doctrine of substantial compliance

Source: CourtListener parenthetical corpus (CC0).