United States Federal Circuit

Internal Revenue Code section 6404(h) grants exclusive subject matter jurisdiction to the Tax Court to review the IRS's denials of interest abatement. Dismissal of plaintiffs' suit for lack of jurisdiction is affirmed where the United States Court of Federal Claims lacked subject matter jurisdiction over taxpayer-plaintiffs' interest abatement claim.

Appellate Information

• Decided 05/04/2006
• Published 05/04/2006

Judges

• LOURIE, Circuit Judge., Before LOURIE, LINN, and DYK, Circuit Judges.

Court

• United States Federal Circuit

Counsel

• For Appellant:
  
• Teresa J. Womack, Redding & Associates, P.C., of Houston, Texas, argued for plaintiffs-appellants.   With her on the brief was Sallie W. Gladney.


• For Appellees:
  
• Bethany B. Hauser, Attorney, Tax Division, United States Department of Justice, of Washington, DC, argued for defendant-appellee.   With her on the brief were Eileen J. O'Connor, Assistant Attorney General, and Kenneth L. Greene, Attorney.   Of counsel was Marion E.M. Erickson.