Hinck v. United States

delivered the opinion of the Court.

Bad things happen if you fail to pay federal income taxes when due. One of them is that interest accrues on the un

The Internal Revenue Code provides that if any amount of assessed federal income tax is not paid “on or before the last date prescribed for payment,” interest “shall be paid for the period from such last date to the date paid.” 26 U. S. C. § 6601 (a). Section 6404 of the Code authorizes the Secretary of the Treasury to abate any tax or related liability in certain circumstances. As part of the Tax Reform Act of 1986, Congress amended §6404 to add subsection (e)(1), which, as enacted, provided in pertinent part:

“In the ease of any assessment of interest on . . . any deficiency attributable in whole or in part to any error or delay by an officer or employee of the Internal Revenue Service (acting in his official capacity) in performing a ministerial act... the Secretary may abate the assessment of all or any part of such interest for any period.” 26 U. S. C. § 6404 (e)(1) (1994 ed.).

In the years following passage of § 6404(e)(1), the federal courts uniformly held that the Secretary’s decision not to grant an abatement was not subject to judicial review. See,

In 1996, as part of the Taxpayer Bill of Rights 2, Congress again amended §6404, adding what is now subsection (h). As relevant, that provision states:

“Review of denial of request for abatement of interest “(1) In general

“The Tax Court shall have jurisdiction over any action brought by a taxpayer who meets the requirements referred to in section 7430(c)(4)(A)(ii) to determine whether the Secretary’s failure to abate interest under this section was an abuse of discretion, and may order an abatement, if such action is brought within 180 days after the date of the mailing of the Secretary’s final determination not to abate such interest.” 26 U. S. C. § 6404 (h)(1) (2000 ed., Supp. IV).

Section 7430(c)(4)(A)(ii) in turn incorporates 28 U. S. C. § 2412 (d)(2)(B), which refers to individuals with a net worth not exceeding $2 million and businesses with a net worth not exceeding $7 million. Congress made subsection (h) effective for all requests for abatement submitted to the IRS

Ill

Our analysis is governed by the well-established principle that, in most contexts, “ ‘a precisely drawn, detailed statute pre-empts more general remedies.’” EC Term of Years Trust v. United States, ante, at 433 (quoting Brown v. GSA, 425 U. S. 820 , 834 (1976)); see also Block v. North Dakota ex rel. Board of Univ. and School Lands, 461 U. S. 273 , 284-286 (1983). We are also guided by our past recognition that when Congress enacts a specific remedy when no remedy was previously recognized, or when previous remedies were “problematic,” the remedy provided is generally regarded as exclusive. Id., at 285 ; Brown, supra, at 826-829 .

Section 6404(h) fits the bill on both counts. It is a “precisely drawn, detailed statute” that, in a single sentence, provides a forum for adjudication, a limited class of potential plaintiffs, a statute of limitations, a standard of review, and authorization for judicial relief. And Congress enacted this provision against a backdrop.of decisions uniformly rejecting the possibility of any review for taxpayers wishing to challenge the Secretary’s § 6404(e)(1) determination. Therefore, despite Congress’s failure explicitly to define the Tax Court’s jurisdiction as exclusive, we think it quite plain that the terms of § 6404(h) — a “precisely drawn, detailed statute” filling a perceived hole in the law — control all requests for review of § 6404(e)(1) determinations. Those terms include the forum for adjudication.

It is true that by providing an abuse-of-discretion standard, Congress removed one of the obstacles courts had held foreclosed judicial review of § 6404(e)(1) determinations. See, e. g., Argabright, 35 F. 3d, at 476 (noting an absence of “ ‘judicially manageable standards’ ” (quoting Heckler, 470 U. S., at 830 )). But in enacting § 6404(h), Congress did not simply supply this single missing ingredient; rather, it set out a carefiilly circumscribed, time-limited, plaintiff-specific provision, which also precisely defined the appropriate forum. We cannot accept the Hincks’ invitation to isolate one feature of this “precisely drawn, detailed statute” — the portion specifying a standard of review — and use it to permit taxpayers to circumvent the other limiting features Congress placed in the same statute — restrictions such as a shorter statute of limitations than general refund suits, compare § 6404(h) (180-day limitations period) with § 6532(a)(1) (2-year limitations period), or a net-worth ceiling for plaintiffs eligible to bring suit. Taxpayers could “effortlessly evade” these specific limitations by bringing interest abate

The Hincks7 other contentions are equally unavailing. First, they claim that reading § 6404(h) to vest exclusive jurisdiction in the Tax Court impliedly repeals the pre-existing jurisdiction of the district courts and Court of Federal Claims, despite our admonition that “repeals by implication are not favored.” Morton v. Mancari, 417 U. S. 535 , 549 (1974) (internal quotation marks omitted). But the implied-repeal doctrine is not applicable here, for when Congress passed § 6404(h), § 6404(e)(1) had been interpreted not to provide any right of review for taxpayers. There is thus no indication of any “language on the statute books that [Congress] wishe[d] to change,” United States v. Fausto, 484 U. S. 439 , 453 (1988), implicitly or explicitly. Congress simply prescribed a limited form of review where none had previously been found to exist.

Second, the Hincks assert that vesting jurisdiction over § 6404(e)(1) abatement decisions exclusively in the Tax Court runs contrary to the “entire structure of tax controversy jurisdiction,” Brief for Petitioners 30, under which the Tax Court generally hears prepayment challenges to tax liability, see § 6213(a), while postpayment actions are brought in the district courts or Court of Federal Claims. In a related vein, the Hincks point out that the Government’s position would force taxpayers seeking postpayment review of their tax liabilities to separate their § 6404(e)(1) abatement claims from their refund claims and bring each in a different court. Even assuming, arguendo, that we were inclined to depart from the face of the statute, these arguments are undercut on two fronts. To begin with, by expressly granting to the Tax Court some jurisdiction over § 6404(e)(1) decisions, Congress has already broken with the general scheme the