434
Opinion of the Court
action, and therefore does not fit the Act's description of suits barred from federal district court adjudication. See Louisiana Land & Exploration Co. v. Pilot Petroleum Corp., 900 F. 2d 816, 818 (CA5 1990) ("The Tax Injunction Act does not bar federal court jurisdiction [of a] suit . . . to collect a state tax.").
Nevertheless, in Keleher v. New England Telephone & Telegraph Co., 947 F. 2d 547 (CA2 1991), the Court of Appeals concluded:
"[I]n removing the federal courts' power to 'enjoin, suspend or restrain' state and local taxes, [Congress] necessarily intended for federal courts to abstain from hearing tax enforcement actions in which the validity of a state or local tax might reasonably be raised as a defense." Id., at 551.4
We do not agree that the Act's purpose requires us to disregard the text formulation Congress adopted.
Congress modeled the Tax Injunction Act, which passed in 1937, upon previously enacted federal "statutes of similar import," measures that parallel state laws barring "actions in State courts to enjoin the collection of State and county taxes." S. Rep. No. 1035, 75th Cong., 1st Sess., 1 (1937). The federal statute Congress had in plain view was an 1867 measure depriving courts of jurisdiction over suits brought "for the purpose of restraining the assessment or collection" of any federal tax. Act of Mar. 2, 1867, ch. 169, § 10, 14 Stat. 475, now codified at 26 U. S. C. § 7421(a) (1994 ed., Supp. III). The 1867 provision, of course, does not bar federal-court ad-4 The Second Circuit further stated that "[e]ven if Congress did not intend the Act's jurisdictional bar to reach so far, . . . we believe that general principles of federal court abstention would nonetheless require us to stay our hand here." 947 F. 2d, at 551. Keleher was a diversity action raising " 'difficult questions of state law bearing on policy problems of substantial public import.' " Ibid. (quoting Colorado River Water Conservation Dist. v. United States, 424 U. S. 800, 814 (1976)). See infra, at 435, n. 5.
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