CIC Servs. v. IRS

The Supreme Court unanimously decided that the Anti-Injunction Act does not block lawsuits challenging IRS reporting requirements backed by tax penalties. It said challenging a regulation is different from seeking to stop tax collection.

Justice Kagan wrote the 9–0 opinion, joined by Chief Justice Roberts and Justices Thomas, Breyer, Alito, Gorsuch, and Barrett; Justices Sotomayor and Kavanaugh concurred.

The Court decided the case unanimously. No opinion author, concurrences, or dissents are identified here.

Majority

Kagan

Roberts

Thomas

Breyer

Alito

Sotomayor

Gorsuch

Kavanaugh

Barrett

Businesses and other taxpayers can challenge IRS reporting mandates without first violating the rule and paying a penalty. For example, a company facing a reporting requirement may bring a lawsuit over the rule itself.

The Court has finished its action in this case. Taxpayers challenging similar IRS regulatory mandates may seek to bring their claims without first paying a related penalty.

The Court said the Anti-Injunction Act does not bar lawsuits challenging IRS reporting requirements backed by tax penalties.

Businesses and taxpayers subject to IRS reporting mandates may challenge those rules without first violating them and paying a penalty.

The Supreme Court has completed the case. Similar challenges to IRS regulatory requirements can proceed under the Court's interpretation.