U.S. District Judge William Smith said Hatch had failed to refile his 2000 and 2001 tax returns as required in his 2006 sentencing. However, Smith did not immediately send Hatch back to jail.
Hatch was convicted of failing to pay taxes on the $1 million prize he won on the debut season of "Survivor."
According to the IRS, Hatch now owes about $1.7 million in taxes for those years, including interest and penalties.
Smith said he would sentence Hatch after receiving additional written arguments from lawyers on both sides.
The Associated Press contributed to this report.
