Arkansas v. Farm Credit Servs. of Central Ark., 520 U.S. 821, 6 (1997)

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826

ARKANSAS v. FARM CREDIT SERVS. OF CENTRAL ARK.

Opinion of the Court

an action filed in a United States District Court to challenge state taxes we held that the Tax Injunction Act "deprived the District Court of jurisdiction to hear [the] challenges." California v. Grace Brethren Church, 457 U. S. 393, 396 (1982). Further, we found no jurisdiction even though the defendant State argued in favor of the federal court's jurisdiction. Id., at 417, n. 38. In explaining our holding in Grace Brethren that declaratory relief is as violative of the Tax Injunction Act as an injunction itself, we said the Act was first and foremost a vehicle " 'to limit drastically federal district court jurisdiction to interfere with so important a local concern as the collection of taxes.' " Id., at 408-409 (quoting Rosewell v. LaSalle Nat. Bank, 450 U. S. 503, 522 (1981)). These statements underscore the fundamental importance of the restrictions imposed by the Tax Injunction Act, restrictions we proceed to address.

II

The federal balance is well served when the several States define and elaborate their own laws through their own courts and administrative processes and without undue interference from the Federal Judiciary. The States' interest in the integrity of their own processes is of particular moment respecting questions of state taxation. In our constitutional system, the power of the State to tax is a concurrent power. "That the power of taxation is one of vital importance; that it is retained by the States; that it is not abridged by the grant of a similar power to the government of the Union; that it is to be concurrently exercised by the two governments: are truths which have never been denied." McCulloch v. Maryland, 4 Wheat. 316, 425 (1819). The power to tax is basic to the power of the State to exist. Wisconsin v. J. C. Penney Co., 311 U. S. 435, 444 (1940); Rosewell, supra, at 522.

Enactment of the Tax Injunction Act of 1937 reflects a congressional concern to confine federal-court intervention

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