On Jan. 12, 2007, the Supreme Court agreed to determine whether disputes with the IRS over abatement of interest on income tax deficiencies may be brought in any federal district court, or only in the Tax Court. A 1996 law expressly authorized the Tax Court to handle these cases, but Congress did not alter another law that gives other federal courts jurisdiction over the erroneous imposition of taxes.
On May 21, 2007, the Court decided that the Tax Court provides exclusive jurisdiction for judicial review of a failure to abate interest under ยง 6404(e)(1). Congress clearly set the forum and other requirements for such challenges. The Court found it appropriate that the Tax Court review abatement issues, which involve an evaluation of the internal processes of the IRS, while allowing other courts to handle issues relating to substantive tax law. Even though it may not be as efficient, there is nothing "tellingly awkward" about it.