District of Columbia Office of Tax and Revenue v. John R. Shuman and Sara G. Shuman, 82 A.3d 58

Shumans timely filed a DC tax protest for 2004 after an erroneous $790 refund was mis-recorded as a tax due.
OTR later admitted the 2004 liability claim was unfounded, but continued erroneous offset notices against the Shumans.
OTR’s computer glitch generated ongoing notices and refunds related to 2004 that affected 2007 otherwise.
ALJ ordered extensive monetary and equitable relief, including an injunction-like directive to repair the system and large monetary sanctions.
The DC Court of Appeals reviews whether OAH had jurisdiction and whether its remedial orders were lawful, reversing the ALJ on authority and sanctions grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether OAH had jurisdiction to order refunds/off-sets related to 2004	Shumans argue OAH had jurisdiction under the Tax Clarity Act and Establishment Act.	OTR contends OAH only handles protests of proposed assessments, not refunds; therefore no jurisdiction.	OAH had jurisdiction; notices were treated as proposed deficiencies and subject to OAH review.
Whether OAH had authority to order remedial measures and sanctions	Shumans contend sanctions were necessary to curb repeated errors and protect the process.	OTR asserts ALJ exceeded authority; sanctions amounted to improper equitable relief and contempt-like remedies.	ALJ exceeded authority; equitable injunctions and ongoing fines cannot be imposed by an administrative agency.

Ramos v. District of Columbia Dep’t of Consumer & Regulatory Affairs, 601 A.2d 1069 (D.C. 1992) (agency lacks inherent equitable authority; must stay within statutory powers)
District Intown Props., Ltd. v. District of Columbia Dep’t of Consumer & Regulatory Affairs, 680 A.2d 137 (D.C. 1996) (courts determine limits of agency statutory authority ultra vires nullity)
EDM & Assocs. v. Gem Cellular, 597 A.2d 384 (D.C. 1991) (labels not controlling; substance governs legal consequence)
Interstate Commerce Comm’n v. Brimson, 154 U.S. 447 (U.S. 1894) (agency contempt power cannot be used by administrative agencies; must rely on courts)
Glus v. Brooklyn E. Dist. Terminal, 359 U.S. 231 (U.S. 1959) (equitable relief limitations; separation of powers considerations)
Scott v. United States, 559 A.2d 745 (D.C. 1989) (appearance of impartiality concerns in agency actions)
Mullin v. District of Columbia Rental Hous. Comm’n, 844 A.2d 1138 (D.C. 2004) (illustrates regulatory authority limits in agency actions)