Alexander v. ''Americans United'' Inc
In Alexander v. ''Americans United'' Inc., 416 U.S. 752 (1974), the IRS had revoked the tax exempt status of Americans United, which affected the organizations tax liability and the ability of the organizations donors to deduct contributions from their taxes.
In an effort to avoid the AntiInjunction Acts bar, Americans United styled its suit as an objection to the laws under which its tax-exempt status was revoked rather than to its increased tax burden. Id. at 755-58.
Americans United argued that its suit would have at best a collateral effect on the assessment or collection of taxes. Id. at 760. It therefore contended that the suit was not barred by the Anti-Injunction Act. The Supreme Court disagreed.
The Court explained that if Americans United prevailed, its tax exempt status would be reinstated and the United States would necessarily collect fewer taxes from the organization and its charitable contributors. A suit to enjoin the assessment or collection of anyones taxes triggers the literal terms of the Act. Id.
The Supreme Court said it would be circular to conclude that a regulatory challenge that would preclude the collection of taxes was not a suit for the purpose of restraining the collection of those taxes. Id. at 761.