Arkansas v. Farm Credit Servs. of Central Ark., 520 U.S. 821, 9 (1997)

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Cite as: 520 U. S. 821 (1997)

Opinion of the Court

same as those of the United States. We conclude here, as we did in Moe, that this argument is insufficient to justify an exception to the Tax Injunction Act.

True, important consequences flow from the congressional decision to designate a PCA formed pursuant to statute as "an instrumentality of the United States." 12 U. S. C. § 2071(b)(7). The tax immunity a PCA has under § 2077 is a permitted consequence of its status as a federal instrumentality. An instrumentality of the United States can enjoy the benefits and immunities conferred by explicit statutes, however, without the further inference that the instrumentality has all of the rights and privileges of the National Government.

Respondents attempt to counter this point by arguing that NLRB v. Nash-Finch Co., 404 U. S. 138 (1971), is applicable here and supports their cause. Nash-Finch involved not the Tax Injunction Act, but the Anti-Injunction Act, the statute which restricts the authority of federal courts to enjoin proceedings in state courts. 28 U. S. C. § 2283. The Anti-Injunction Act provides: "A court of the United States may not grant an injunction to stay proceedings in a State court except as expressly authorized by Act of Congress, or where necessary in aid of its jurisdiction, or to protect or effectuate its judgments." Just as the Tax Injunction Act is inapplicable where the United States is a party, a parallel rule prevails under § 2283. Leiter Minerals, Inc. v. United States, 352 U. S. 220, 225-226 (1957) (The restrictions of § 2283 are inapplicable in a suit brought by the National Government). The question in Nash-Finch was whether the National Labor Relations Board (NLRB) came within the United States' exception to § 2283. We held it did. In so ruling, we observed the NLRB's regulatory power "pre-empts the field." 404 U. S., at 144; see also id., at 147 ("The exclusiveness of the federal domain is clear . . ."). The case does not aid the PCA's, for their powers are far different from those of the NLRB. As will be discussed in more detail below, the

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