Strategic Housing Finance Corp. of Travis County 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 taxpayers must comply with the administrative refund scheme established in the Internal Revenue Code
• holding that “a party seeking to recover any internal-revenue tax, penalty, or sum from the United States must pursue and exhaust its administrative remedies pursuant to the IRS’s regulations prior to filing a complaint in federal court”
• holding that “a party seeking to recover any internal-revenue tax, penalty, or sum from the United States must pursue and exhaust its administrative remedies pursuant to the IRS’s regulations prior to filing a complaint in federal court”
• noting that when the Court of Federal Claims lacks subject matter jurisdiction, it should not have analyzed the agency’s actions under the Administrative Procedure Act
• finding that Clintwood “unequivocally concludes that the jurisdictional bar contained in section 7422(a) applies regardless of the underlying characterization of the claim.”
• “the plain meaning of . . . § 7422(a) demonstrated that Congress required a party seeking a tax refund for any reason [to] fil[e] a refund claim with the IRS.”

Source: CourtListener parenthetical corpus (CC0).