1、CRS Legal Sidebar Prepared for Members and Committees of Congress Legal SidebarLegal Sidebari i CIC Services v. Commissioner: Interpreting the Tax Anti-Injunction Act February 23, 2021 On December 1, 2020, the Supreme Court heard oral argument in CIC Services v. Commissioner, a case that could resol
2、ve conflicts resulting from the way courts have interpreted the Tax Anti-Injunction Act (TAIA) in the past. The TAIA is codified in Section 7421 of the Internal Revenue Code (IRC). It is a narrow exception to the general administrative law rule permitting pre-enforcement judicial review of administr
3、ative actions in federal courts. The TAIA protects federal revenues and supports efficient tax administration by postponing litigation to contest tax assessment and collection. Subject to a few exceptions, the TAIA requires lawsuits challenging taxes to be made only after paying the disputed tax and
4、 filing a claim for refund. The petitioner in CIC Services claims that the TAIA, as originally understood, does not bar a pre-enforcement challenge to an Internal Revenue Service (IRS) notice containing reporting requirements that are enforced through a tax penalty. This Legal Sidebar provides backg
