Jefferson County v. Acker, 527 U.S. 423, 13 (1999)

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Cite as: 527 U. S. 423 (1999)

Opinion of the Court

judication of suits initiated by the United States to collect federal taxes; it precludes only suits brought by taxpayers to restrain the United States from assessing or collecting such taxes. Similarly, the state laws to which Congress referred surely do not preclude the States from enforcing their taxes in court.

The Tax Injunction Act was thus shaped by state and federal provisions barring anticipatory actions by taxpayers to stop the tax collector from initiating collection proceedings. It was not the design of these provisions to prohibit taxpayers from defending suits brought by a government to obtain collection of a tax. Congress, it appears, sought particularly to stop out-of-state corporations from using diversity jurisdiction to gain injunctive relief against a state tax in federal court, an advantage unavailable to in-state taxpayers denied anticipatory relief under state law. See S. Rep. No. 1035, supra, at 2. In sum, we hold that the Tax Injunction Act, as indicated by its terms and purpose, does not bar collection suits, nor does it prevent taxpayers from urging defenses in such suits that the tax for which collection is sought is invalid.5

IV

The Eleventh Circuit held that Jefferson County's license tax, as applied to federal judges, amounts to "a direct tax on the federal government or its instrumentalities" in violation of the intergovernmental tax immunity doctrine. Jefferson

5 As noted in Keleher v. New England Telephone & Telegraph Co., 947 F. 2d 547, 551 (CA2 1991), see supra, at 434, n. 4, abstention and stay doctrines may counsel federal courts to withhold adjudication, according priority to state courts on questions concerning the meaning and proper application of a state tax law. Cf. Burford v. Sun Oil Co., 319 U. S. 315, 332-334 (1943); Quackenbush v. Allstate Ins. Co., 517 U. S. 706, 719-721 (1996) (in a case seeking damages, rather than equitable relief, a federal court may not abstain, but can stay the action pending resolution of the state-law issue). No one has argued for the application of such doctrines here.

435

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