Bob Jones University v. Simon

In Bob Jones Univ. v. Simon, 416 U.S. 725, 94 S.Ct. 2038, 40 L.Ed.2d 496 (1974), the Supreme Court made clear that the AIA prohibits courts from entertaining pre-enforcement suits challenging the IRS's assessment or collection of federal taxes. The Court held that filing these forward-looking suits, as opposed to paying the taxes arising from the dispute, then claiming a refund, was contrary to the clear terms of the AIA preventing courts from entertaining any "suit for the purpose of restraining the assessment or collection of any tax." Id. at 736, 94 S.Ct. 2038 (quoting 26 U.S.C. 7421(a)). The Court noted that although the AIA "apparently has no recorded legislative history," id., its "principal purpose" is "the protection of the Government's need to assess and collect taxes as expeditiously as possible with a minimum of preenforcement judicial interference, `and to require that the legal right to the disputed sums be determined in a suit for refund.'" Id. at 736-37, 94 S.Ct. 2038 (quoting Enochs v. Williams Packing and Navigation Co., 370 U.S. 1, 7, 82 S.Ct. 1125, 8 L.Ed.2d 292 (1962)). In Bob Jones University v. Simon, 416 U.S. 725, 94 S.Ct. 2038, 40 L.Ed.2d 496 (1974), the Court held that the Act prevented a court from enjoining the Service where the Service had revoked a letter ruling of tax exempt status. The Court held, inter alia, that the Service's action would require the taxpayer to pay the Federal Insurance Contributions Act (FICA) and Federal Unemployment Tax Act (FUTA) taxes and would increase donors' tax liability because their contributions would no longer be deductible. Thus, the Court reasoned, permitting the injunction would restrain the collection of these taxes. 416 U.S. at 738-742, 94 S.Ct. at 2046-2048.