Hoogerheide v. Internal Revenue Service

OPINION

SUTTON, Circuit Judge.

After the Internal Revenue Service sold Kenneth Hoogerheide’s property to offset unpaid taxes, Hoogerheide sued the IRS and several of its employees. Many of the claims fell by the wayside for one reason or another, leaving a money-damages claim against the United States, which the district court dismissed for lack of jurisdiction. We affirm the dismissal, though not the explanation, as Hoogerheide’s failure to exhaust the IRS’s administrative remedies did not deprive the court of jurisdiction over the damages claim.

I

Hoogerheide, like most everyone, owed the IRS…