Justia U.S. 6th Circuit Court of Appeals Opinion Summaries

The IRS auctioned the taxpayer's property for back taxes. Letters sent by the taxpayer, in an attempt to resolve or appeal the decision, were incorrectly addressed. The district court dismissed a suit for damages. The Sixth Circuit affirmed, but held that failure to exhaust administrative remedies (26 U.S.C. 7433)did not deprive the court of jurisdiction. What is mandatory is not necessarily jurisdictional; the context shows that the requirement is a limit on relief.