hibbs director arizona department revenue winn et argued january decided june counsel record petitioner hibbs joseph kanefield arizona attorney general office phoenix az respondents winn et al marvin cohen sacks tierney pa scottsdale az arizona taxpayers filed suit federal director arizona department revenue director seeking enjoin operation rev stat ann establishment clause grounds arizona law authorizes credit payments nonprofit school tuition organizations stos award scholarships students private elementary secondary schools section provides stos may designate schools discriminate basis race color handicap familial status national origin preclude stos designating schools provide religious instruction give admissions preferences district granted director motion dismiss ground tax injunction act tia barred suit tia prohibits lower federal courts restraining assessment levy collection tax state law plain speedy efficient remedy may courts state ninth circuit reversed holding tia bar actions challenging state tax credits held rejects respondents contention director certiorari petition jurisdictionally untimely rule section instructs petition must filed within ninety days entry judgment rule elaborates statute instruction days elapsed date ninth circuit first entered judgment date director petition filed time lapse respondents assert made filing untimely rule first sentence time file runs date entry judgment order sought reviewed moreover respondents submit party petitioned rehearing extended filing periods prescribed rule second sentence never came play case however follow typical course ninth circuit initiative recalled mandate ordered parties brief question whether case reheard en banc order holds suspended judgment finality timely filed rehearing petition appropriate decision consider rehearing petition see missouri jenkins appeals order raised question whether modify judgment alter parties rights thus briefing order pending judgment reviewed see director certiorari petition timely statute filed within days date ninth circuit denied rehearing en banc read rule sole guide party rehearing petition reset statute count lose sight congressional objective underpinning appellate final adjudication congress indicated marks time filing period begins run statute takes priority procedural rules adopted orderly transaction business schacht petition timely jurisdiction pp tia bar respondents suit pp determine whether tia bars litigation appropriate first identify relief sought respondents seek prospective relief injunctive relief prohibiting director allowing taxpayers utilize tax credit payments stos make tuition grants declaration face applied violates establishment clause order director inform stos funds possession order date must paid state general fund taking account prospective nature relief requested reaches dispositive question whether respondents suit seeks enjoin suspend restrain assessment levy collection tax state law answer turns meaning term assessment employed tia internal revenue code irc purposes assessment involves recording amount taxpayer owes government focus word assessment isolation however follows cardinal rule statutory language must read context general dynamics land systems cline tia tax law generally assessment closely tied collection tax assessment official recording liability triggers levy collection efforts complementing cardinal rule stated rule superfluities instructs courts interpret statute effectuate provisions part rendered superfluous director asserts term assessment signified entire taxing plan tia need words levy collection term assessment alone necessary work briefing galletti government made clear irc definition assessment serves trigger levy collection efforts government describe assessment synonymous entire taxation plan disassociate word company levy collection keeps instead accord understanding government related assessment term function pp congress modeled earlier federal statutes similar import turn paralleled state provisions proscribing actions enjoin collection state local taxes congress drew particularly act aia bars entertaining suit brought purpose restraining assessment collection federal tax recognized aia text measure serves twin purposes responds government need assess collect taxes expeditiously minimum preenforcement judicial interference requires legal right disputed sums determined refund suit bob jones univ simon lower federal courts similarly comprehended aia shields federal tax collections injunctions tia shields state tax collections restraints congress directed taxpayers pursue refund suits instead attempting restrain collections suits seeking stop collection contest validity tax imposed plaintiffs outside congress purview tia legislative history shows enacting statute congress focused taxpayers sought avoid paying state tax bill pursuing challenge route one specified taxing authority nowhere history announce sweeping congressional direction prevent interference aspects state tax administration foregoing understanding tia purposes legislative history underpins previous applications statute see california grace brethren church distinguished contrary director assertion arkansas farm credit servs central national private truck council oklahoma tax fair assessment real estate mcnary rosewell lasalle nat bank hold state tax administration matters must kept entirely free lower interference like grace brethren church cases fall within undisputed compass involved plaintiffs mounted federal litigation avoid paying state taxes gain refund taxes relief therefore operated reduce flow state tax revenue decisions fairly portrayed cut loose secure moorings see grace brethren church interpreted applied tia cases congress wrote statute address cases state taxpayers seek orders enabling avoid paying state taxes read harmoniously instruction conditioning jurisdictional bar availability plain speedy efficient remedy state remedy inspected decisions designed universe plaintiffs sue state taxpayers see pp federal courts well read restrain taxpayers instituting federal actions contest liability state taxes stop third parties pursuing constitutional challenges state tax benefits federal forum numerous decisions including decisions reviewing lower judgments reached merits constitutional challenges tax benefits without mentioning tia see byrne public funds public schools new jersey griffin school bd prince edward consistent understanding prevailing issue respondents suit may proceed without tia impediment pp affirmed ginsburg delivered opinion stevens souter breyer joined stevens filed concurring opinion kennedy filed dissenting opinion rehnquist scalia thomas joined elliott hibbs director arizona ment revenue petitioner kathleen winn et al writ certiorari appeals ninth circuit june justice ginsburg delivered opinion arizona law authorizes credits payments organizations award educational scholarships tuition grants children attending private schools see rev stat ann west supp plaintiffs respondents brought action federal challenging seeking enjoin operation establishment clause grounds question presented whether tax injunction act tia act prohibits lower federal restraining assessment levy collection tax state law bars suit contest tax liability seek impede arizona receipt tax revenues suit hold kind proscribes decisions spanning near half century courts federal system including entertained challenges tax credits authorized state law without conceiving jurisdictional barrier first occasion squarely confront issue confirm authority federal courts exercised cases hardly ancient history bent maintaining racial segregation public schools allocating resources disproportionately benefit white students detriment black students fastened tion grants tax credits promising means circumvent brown board education federal courts among adjudicated ensuing challenges instituted upheld constitution equal protection requirement see griffin school bd prince edward faced unconstitutional closure county public schools tuition grants tax credits contributions private segregated schools district require county levy taxes fund nondiscriminatory public schools abstention required state courts determine validity grants tax credits closing allen county school bd prince edward supp ed county enjoined paying grants providing tax credits support private schools exclude students based race public schools remain closed supp ed closure public schools enjoined see also moton lambert supp nd miss challenge tax exemptions racially discriminatory private schools may proceed federal instant case petitioner hibbs director arizona department revenue argues effect federal courts wrong cases tia petitioner maintains trumps act according petitioner bars lower interference state tax systems even challengers endeavoring avoid tax imposed matter whether state revenues raised lowered plaintiffs prevail alleged jurisdictional bar petitioner asserts existed since tia enactment even imagined jurists pathmarking cases cited defendants cases litigants every interest defeating adjudicatory authority prior decisions command respect petitioner urges constitute mere sub silentio holdings reply brief petitioner reject assessment examine opinion scope term assessment used tia question whether act intended insulate state tax laws constitutional challenge lower federal courts even suit negative impact tax collection concluding suit implicates neither conception assessment statute underlying purposes affirm judgment appeals arizona taxpayers filed suit district district arizona challenging rev stat ann west supp incompatible establishment clause section provides credit taxpayers contribute money school tuition organizations stos sto nonprofit organization directs moneys form scholarship grants students enrolled private elementary secondary schools stos must disburse scholarship grants least percent contributions received may allow donors direct scholarships individual students may allow donors name dependents must designate least two schools whose students receive funds must designate schools discriminate basis race color handicap familial status national origin see stos precluded arizona statute designating schools provide religious instruction give admissions preference basis religion religious affiliation taxpayers donate money qualified sto allows calculating arizona tax liability credit donation married couple filing jointly effect gives arizona taxpayers election may direct filers sto arizona department revenue long donors give stos total tax liability contributions costless arizona vote rejected facial challenge statute went effect kotterman killian en banc case took form special discretionary action invoking original jurisdiction see kotterman undisputed preclusive effect instant challenge brought different plaintiffs respondents complaint director arizona department revenue director alleged authorizes formation agencies sole purpose distribution state funds children particular religious denomination children attending schools particular religious denomination complaint app respondents sought injunctive declaratory relief order requiring stos pay funds still possession state general fund app director moved dismiss action relying tia reads entirety district courts shall enjoin suspend restrain assessment levy collection tax state law plain speedy efficient remedy may courts state director assert order enjoining interfere state tax levy collection efforts urged federal injunction restrain assessment taxes state law agreeing director district held tia required dismissal suit app pet cert appeals ninth circuit reversed holding federal action challenging granting state tax credit prohibited tia winn killian far adversely affect ing state ability raise revenue appeals observed relief requested respondents result state receiving funds used public benefit granted certiorari view division opinion whether tia bars constitutional challenges state tax credits federal compare aclu foundation bridges tia bars federal action seeking part state tax system declared unconstitutional affirm judgment ninth circuit ii reaching merits case must address respondents contention director petition certiorari jurisdictionally untimely rules see brief opposition section instructs petition certiorari must filed within ninety days entry judgment rule elaborates time file petition writ certiorari runs date entry judgment order sought reviewed issuance date mandate equivalent local practice petition rehearing timely filed lower party time file petition writ certiorari parties whether requested rehearing joined petition rehearing runs date denial petition rehearing petition rehearing granted subsequent entry judgment respondents assert director petition missed rule deadlines days elapsed date appeals first entered judgment date petition filed rendering filing untimely first sentence rule party petitioned rehearing extended periods prescribed rule second sentence never came play case however follow typical course appeals motion recalled mandate ordered parties brief question whether case reheard en banc order conclude suspended judgment finality timely filed rehearing petition appropriate decision consider rehearing petition compare young harper appeals agreed consider rehearing petition timeliness petition certiorari measured date disposed rehearing petition missouri jenkins time applying certiorari tolled appears lower granted rehearing amended order solely purpose extending timely rehearing petition appropriate decision entertain untimely rehearing petition direction initiative parties address whether rehearing ordered share key characteristic three raise question whether modify judgment alter parties rights see timely petition rehearing operates suspend finality judgment pending determination whether judgment modified alter adjudication rights parties quoting department banking neb pink per curiam alterations original words petition rehearing pending considering initiative whether rehearing ordered reviewed jenkins light hold director petition writ certiorari timely appeals ordered briefing rehearing issue days yet passed issuance panel opinion limit yet expired clock still reset order left unresolved whether modify judgment briefing order effect genuinely final judgment critical statute must treat date order denying rehearing en banc date judgment entered petition filed within days date thus timely statute read rule sole guide rehearing petition filed party reset statute count lose sight congressional objective underpinning appellate final adjudication congress indicated marks time period allowed certiorari petition begins run statute takes priority procedural rules adopted orderly transaction business schacht rules fail anticipate unusual circumstances fit securely within federal statute compass statute controls decision see kontrick ryan slip axiomatic procedural rules create withdraw federal jurisdiction quoting owen equipment erection kroger petition writ certiorari timely jurisdiction decide whether tia bars respondents suit iii determine whether litigation falls within tia prohibition appropriate first identify relief sought respondents seek prospective relief specifically complaint requests injunctive relief prohibiting director allowing taxpayers utilize tax credit authorized payments made stos make tuition grants children attending religious schools children attending schools one religious denomination children selected basis religion complaint app respondents ask declaration face applied violates establishment clause affirmatively authorizing stos use state revenues pay tuition students attending religious schools schools discriminate basis religion ibid finally respondents seek order director inform stos funds possession date order must paid state general fund complaint app taking account prospective nature relief requested respondents suit words seek enjoin suspend restrain assessment levy collection tax state law answer question turns meaning term assessment employed used internal revenue code irc term assessment involves recording amount taxpayer owes government assessment essentially bookkeeping notation laing section irc authorizes secretary treasury make assessments taxes imposed title assessment made recording liability taxpayer office secretary accordance rules regulations prescribed secretary see also saltzman irs practice procedure pp ed internal revenue service signs summary list assessment record amount tax liability official act assessment occurred purposes code focus word assessment isolation however instead follow cardinal rule statutory language must read context since phrase gathers meaning words around general dynamics land systems cline slip internal quotation marks omitted tax law generally assessment closely tied collection tax assessment official recording liability triggers levy collection efforts rule superfluities complements principle courts interpret words statute context see singer statutes statutory construction pp rev ed statute construed effect given provisions part inoperative superfluous void insignificant footnotes omitted director asserts term assessment signified entire plan scheme fixed upon charging taxing brief petitioner quoting webster new international dictionary english language ed tia need words levy collection term assessment alone necessary work earlier term galletti government identified two important consequences follow irs timely tax assessment irs may employ administrative enforcement methods tax liens levies collect outstanding tax see time within irs may collect tax either administratively extended years years date assessment see brief galletti pp government thus made clear briefing galletti irc definition tax assessment serves trigger levy collection efforts government describe term synonymous entire plan taxation disassociate word assessment company levy collection word instead accord understanding government related assessment term function iv congress modeled upon earlier federal statutes similar import laws turn paralleled state provisions proscribing actions state courts enjoin collection state county taxes hereinafter composing tia text congress drew particularly measure sometimes called act aia bars entertaining suit brought purpose restraining assessment collection federal tax act mar ch stat codified see jefferson county acker apparently recorded legislative history bob jones univ simon recognized aia text measure serves twin purposes responds government need assess collect taxes expeditiously possible minimum preenforcement judicial interference legal right disputed sums determined suit refund ibid quoting enochs williams packing nav lower federal courts similarly comprehended see mcglotten connally supp dc bar action seeking enjoin exemptions fraternal orders exclude nonwhites membership action plaintiff contest amount tax seek limit amount tax revenue collectible omitted tax analysts advocates shultz supp dc bar challenge irs revenue ruling allowing contributors political candidate committees avoid federal gift tax contributions excess ceiling precludes suits restrain assessment collection taxes proscription apply plaintiffs seek restrain commissioner ing taxes rather require collect additional taxes according mandates law emphases original aia shields federal tax collections injunctions tia shields state tax collections restraints congress directed taxpayers pursue refund suits instead attempting restrain collections suits seeking stop collection contest validity tax imposed plaintiffs mcglotten tax analysts explained outside congress purview tia legislative history silent regard act designed expressly restrict jurisdiction district courts suits relating collection state taxes specifically senate report commented act two closely related objectives eliminate disparities taxpayers seek injunctive relief federal usually corporations asserting diversity jurisdiction taxpayers recourse state courts generally required taxpayers pay first litigate later stop taxpayers aid federal injunction withholding large sums thereby disrupting state government finances see fallon meltzer shapiro hart wechsler federal courts federal system ed citing rosewell lasalle nat bank nn see also jefferson county observing tia shaped state federal provisions barring anticipatory actions taxpayers stop tax collector initiating collection proceedings short enacting tia congress trained attention taxpayers sought avoid paying tax bill pursuing challenge route one specified taxing authority nowhere legislative history announce sweeping congressional direction prevent interference aspects state tax administration brief petitioner post understanding act purposes legislative history set underpins previous applications tia california grace brethren church example recognized principal purpose tia limit drastically interference collection state taxes quoting rosewell brennan concurring part dissenting part complainants grace brethren church several california churches religious schools sought relief unemployment compensation tax state law imposed federal action bypassed state remedies exactly tia designed ward director dissent endeavor reconstruct grace brethren church precedent proposition tia totally immunizes lower review aspects state tax administration interference collection revenue brief petitioner see post endeavor unavailing given issue grace brethren church context words state tax administration appear director invokes several decisions alleged keep matters state tax administration entirely free lower interference brief petitioner accord post like grace brethren church fall within undisputed compass involved plaintiffs mounted federal litigation avoid paying state taxes gain refund taxes relief therefore operated reduce flow state tax revenue see arkansas farm credit servs central corporations chartered federal law claimed exemption arkansas sales income taxation national private truck council oklahoma tax action seeking prevent oklahoma collecting taxes state imposed nonresident motor carriers fair assessment real estate mcnary taxpayers alleging unequal taxation real property sought inter alia damages measured alleged tax overassessments rosewell state taxpayer alleging property inequitably assessed refused pay state taxes prior decisions fairly portrayed cut loose secure moorings see grace brethren church federal declaratory relief available test state tax assessments state tax administration might thrown disarray taxpayers might escape ordinary procedural requirements imposed state law pendency federal suit collection revenue challenged law might obstructed consequent damage state budget perhaps shift state risk taxpayer insolvency quoting ledesma brennan concurring part dissenting part emphases added rosewell compelling nature considerations identified justice brennan perez underscored dependency state budgets receipt local tax revenues may readily appreciate difficulties encountered county substantial portion rightful tax revenue tied injunction actions sum interpreted applied tia cases congress wrote act address cases state taxpayers seek orders enabling avoid paying state taxes see supra read harmoniously instruction conditioning jurisdictional bar availability plain speedy efficient remedy state remedy inspected decisions one designed universe plaintiffs sue state rather remedy taxpayers see rosewell illinois legal remedy provides property owners paying property taxes protest refund without interest two years speedy efficient remedy tia grace brethren church remedy speedy efficient taxpayer hearing judicial determination may raise constitutional objections tax quoting rosewell federal courts well read restrain state taxpayers instituting federal actions contest liability state taxes stop third parties pursuing constitutional challenges tax benefits federal forum relevant distinction taxpayer claims reduce state revenues claims enlarge state receipts seventh circuit judge easterbrook wrote trenchantly although district concluded applies federal litigation touching subject state taxes neither language legislative history statute supports interpretation text suggest federal courts tread lightly issuing orders might allow local governments raise additional taxes legislative history shows designed ensure federal courts interfere collection taxes long taxpayers opportunity present federal defenses imposition collection taxes legislative history filled concern federal judgments emptying state coffers corporations access diversity jurisdiction obtain remedies unavailable resident taxpayers articulated concern federal courts flogging state local governments collect additional taxes dunn carey emphasis added second circuit judge friendly earlier expressed similar view tia context legislative history lead us conclude speaking congress referring methods similar assessment levy distress execution produce money property directly rather indirectly general use coercive power congress thinking cases taxpayers repeatedly using federal courts raise questions state federal law going validity particular taxes imposed upon wells malloy emphasis added see also jackson county observing held inapplicable efforts require collection additional taxes opposed efforts inhibit collection taxes numerous decisions including decisions reviewing lower judgments reached merits constitutional challenges tax benefits without mentioning tia see byrne public funds public schools new jersey summarily state tax deduction taxpayers children attending nonpublic schools violates establishment clause supp nj franchise tax board california americans public schools summarily affirming judgment striking state statute provided reductions taxpayers sending children nonpublic schools committee public ed religious liberty nyquist state tax benefits parents children attending nonpublic schools violates establishment clause relevant part supp sdny grit wolman summarily kosydar wolman supp sd ohio state tax credits expenses relating children enrollment nonpublic schools violate establishment clause finlator powers state statute exempting christian bibles holy books religions books state tax violates establishment clause luthens bair supp sd iowa state law authorizing tax benefit tuition payments textbook purchases violate establishment clause minnesota civil liberties union roemer supp state law allowing parents public private school students claim part tuition transportation expenses tax deduction violate establishment clause procession cases rationally distinguishable one justice member bar ever raised objection according petitioner case caused us order dismissal action want jurisdiction see mueller allen state tax deduction parents send children parochial schools violate establishment clause byrne americans public schools committee public ed religious liberty wolman griffin consistent understanding prevailing issue respondents suit may proceed without tia reasons stated judgment appeals ninth circuit affirmed elliott hibbs director arizona ment revenue petitioner kathleen winn et al writ certiorari appeals ninth circuit june justice stevens concurring part iv dissent justice kennedy observes years unexamined habit litigants courts lessen obligation correctly interpret statute post merits emphasis however prolonged congressional silence response settled interpretation federal statute provides powerful support maintaining status quo statutory matters judicial restraint strongly counsels waiting congress take initiative modifying rules judges litigants relied see bedroc limited llc slip stevens dissenting federal election nra political victory fund stevens dissenting commissioner fink stevens dissenting runyon mccrary stevens concurring contest dictionary doctrine stare decisis latter clearly wins fine opinion join without reservation consistent views elliott hibbs director arizona ment revenue petitioner kathleen winn et al writ certiorari appeals ninth circuit june justice kennedy chief justice justice scalia justice thomas join dissenting case shows great skepticism state courts ability vindicate constitutional wrongs two points make clear treats diminished disfavored powers rather merely applies statutory text first analysis tax injunction act tia act contrasts literal reading terms second assertion legislative histories support conclusion suits seeking stop collection contest validity tax imposed plaintiffs outside congress purview enacting tia provision tia modeled ante borne sources previously recognized light points today holding probably attributed concern candidly shows animates see ante noting federal courts upheld constitution equal protection requirement circumvented brown board education manipulating tax laws concern seems state courts second rate constitutional arbiters unequal federal counterparts state courts due respect dismissive treatment state courts particularly unjustified since tia express terms provides federal safeguard act lifts bar federal intervention state courts fail provide plain speedy efficient remedy view tia text congressional judgment state courts qualified constitutional arbiters respect state courts deserve disagree majority superseding balance act strikes federal state adjudication agree majority petition certiorari timely see ante submit respectful dissent merits decision today first time considered whether tia bars federal district courts granting injunctive relief prevent giving citizens statutorily mandated state tax credits cases dating back almost years proceeded jurisdictional bar apply tax credit challenges recent decisions said bar applicable compare mueller allen committee public ed religious liberty nyquist griffin school bd prince edward aclu foundation la bridges gillis unexamined custom favors first position statutory text favors latter circumstances careful explanation conclusion necessary end scope purpose act understood terms alone question presented whether tia bars district granting injunctive relief tax credit requires two inquiries first term assessment used must defined second must determine injunction prohibiting director allowing credit enjoin suspend restrain assessment word assessment tia isolated use another federal statute tia modeled provision internal revenue code code see jefferson county acker provision specifies specified since federal courts may restrain enjoin assessment collection federal tax first codified act mar ch stat meaning term assessment code provision discernible reference code sections title et seq chapter title addresses subject assessments sheds light meaning term code section first instructs secretary internal revenue service required make assessments taxes imposed title provides secretary shall assess taxes determined taxpayer secretary section turn sets forth method making assessment assessment shall made recording liability taxpayer office secretary taken together provisions title establish assessment term used must least encompass recording taxpayer ultimate tax liability taxpayer owes government see also laing essentially bookkeeping notation made secretary delegate establishes account taxpayer tax rolls whether secretary delegate today commissioner makes recording basis taxpayer filing form instead chooses rely calculation taxpayer liability via audit irrelevant recording liability government tax rolls assessment tia modeled provision see jefferson county supra incorporates terminology employed provision employs terminology purpose sensible interpret tia terms reference code use term cf lorillard pons congress adopts new law incorporating sections prior law congress normally presumed knowledge interpretation given incorporated law least insofar affects new statute appeals concluded assessment official estimate value income property used calculate tax imposition tax someone winn killian placed principal reliance interpretation dictionary definition entirely misplaced unless definition considered context prior statute advantage statute interpretive guidance lost furthermore defined term unusual way relied dictionary unavailable tia enacted relied definition term consideration assessment definition term related verb form assess examined portion terms definition dictionary used appeals verb defined two ways noted one alternative definitions quite relevant fix determine amount damages tax fine compare random house dictionary english language panel looked different lay dictionary found definition contrary one preferred entire plan scheme fixed upon charging taxing panel considered tax treatises law dictionaries found much accord broader definition even federal income tax code supports broad reading winn killian kleinfeld dissenting denial rehearing en banc omitted guided first internal revenue code assessment minimum recording taxpayers liability state tax rolls tia though federal statute must interpreted matter federal law operates context respect act must interpreted apply evenly various regimes various recording schemes employ therefore irrelevant whether state officials record taxpayer liabilities pen specified location collecting maintaining taxpayers filing forms manner recordkeeping equates determination taxpayer liability state tax rolls assessment whatever method seems agree see ante dictionary definition assessment provides relevant information contemporaneous dictionaries time tia enactment define assessment expansive terms broaden understanding term act bar see webster new international dictionary providing three context relevant definitions term assessment act apportioning determining amount paid valuation property purpose taxation entire plan scheme fixed upon charging taxing see also galletti slip noting code term assessment refers recordings tax liability also calculation tax liability including done taxpayer need decide full scope term assessment tia however present purposes narrow definition term suffices applying narrowest definition tia literal text bars district courts enjoining suspending restraining state recording taxpayer liability tax rolls whether recordings made taxpayer filing forms state calculation taxpayer liability terms enjoin suspend restrain require little scrutiny doubt discrete purposes context tia also common meaning refer actions restrict assessments varying degrees noteworthy term enjoin meaning restrictive sense also meaning affirmative sense black law dictionary current tia enactment gives definition term require command positively direct black law dictionary ed definition may well implicated since order invalidating tax credit seem command collect taxes otherwise collect parties however proceed assumption enjoin means bar unobjectionable make assumption leaving broader definition later consideration respondents argue tia bar injunction seek even credit enjoined director able record enforce taxpayers liabilities see brief respondents fact respondents say credit way director able record enforce higher level liability profit state ibid amount tax payable taxpayers increase hardly characterized injunction restraint assessment process argument however ignores important part act state law district courts shall enjoin suspend restrain assessment tax state law act bars district courts enjoining suspending restraining state recording taxpayer liabilities altogether also bars enjoining suspending restraining state recording taxpayer liability state law mandates section state law integral part state tax statute reflected state tax forms state held part calculus necessary determine tax liability see kotterman killian recording taxpayer liability state law must made accordance said respect every provision state tax law order director record state tax rolls taxpayer liability reflects operation state tax law provision matter bar director recording correct taxpayer liability tia language bars relief bars suit tries avoid conclusion saying recordings constitute assessments must function ante recordings issue function see also ante dissent disconnect word assessment enforcement process wrong recording taxpayer liability state tax rolls course propels collection cases taxpayer payment accompany filing thus accompany assessment literal collection moneys necessary anyone paid taxes must know however owed payment included tax filing state recording one liability state rolls certainly cause subsequent collection efforts filing recording assessment propel collection establishing state legal right taxpayer moneys ii majority offers prior judicial interpretations code similarly worded provision support contrary conclusions statutory text see ante federal courts allowed nontaxpayer suits challenging tax credits proceed face provision controlling cases quite distinguishable plaintiffs cases barred suit available forum claims see mcglotten connally supp dc preferred course raising tax exemption deduction objections suit refund available situation read statute bar present suit see also tax analysts advocates shultz supp dc since plaintiffs seeking restrain collection taxes since obtain relief refund suit bar injunctive relief seek ratified decisions insofar relied limited rationale basis exception statutory bar adjudication see south carolina regan holding provision inapplicable state challenge constitutionality federal tax exemption provision code exempts taxpayer gross income interest earned obligations state amended tax equity fiscal responsibility act stat provision intended bar action congress provided plaintiff alternative legal way challenge validity tax even strict limitation strict enough four members one noted broad sweep njunction provision blackmun concurring judgment three justices went still allowed exception provision literal bar nontaxpayer suits challenging tax exemption provisions due process rights stake see concurring judgment bob jones university recognition complete inaccessibility judicial review might implicate due process concerns provides absolutely basis crafting exception act plaintiff due process right review claim judicial forum contrast provision tia terms ensures adequate forum claims bars tia specially exempts actions heard state courts providing exception instances plain speedy efficient remedy may courts state tia text thus already incorporates check regan concluded read provision even though provision language scarcely explicit prohibiting nontaxpayer suits like one practical effect literal reading tia provides federal district courts stand ready litigants encounter legal practical obstacles challenging state tax credits state courts course stands ready review decisions state courts matters discuss codified exception yet clause crucial represents congressional judgment balance exist respect due administration tax schemes courts interpretation tax laws need constitutional vindication ignore provision ignore congress already balanced interests respondents admit heard state indeed quite similar action previously heard see kotterman killian result tia exception akin recognized regan apply proceed replace congress balancing noted interests iii respondents argue tia policy purposes relatedly federal provision policy purposes discerned legislative histories justify today holding two acts say reflect unitary purpose congress directed taxpayers pursue refund suits instead attempting restrain tax collections ante see also ante concluding act underlying purpose bar suits taxpayers sought avoid paying tax bill see also brief respondents purpose respondents say shows act intended foreclose relief challenges tax credits proposition rests premise tia sole purpose prevent district orders decrease moneys state fiscs legislative histories acts carefully limited manner reading suggests policy argument literal application act terms fails taking federal provision first noted history expressly reflects congressional desire injunctive suits tax collector prohibited regan concurring judgment provision responded grave dangers accompany intrusion injunctive power courts administration revenue generally precludes judicial resolution abstract tax controversies whether brought taxpayer nontaxpayer see also reviewing legislative history provision various amendments related enactments thus provision object bar suits might interrupt process collecting taxes imilarly language history evidence congressional desire prohibit courts restraining aspect tax laws administration majority reading tia legislative history also inconsistent interpretation history earlier cases made clear tia purpose protect fisc also protect state tax system administration tax policy implementation california grace brethren church prime example grace brethren church held tia bars actions individuals stop tax collectors collecting moneys injunctive suits also bars declaratory suits see explained permitting declaratory suits proceed defea principal purpose tax injunction act limit drastically federal district jurisdiction interfere important local concern collection taxes quoting rosewell lasalle nat bank continued federal declaratory relief available test state tax assessments state tax administration might thrown disarray taxpayers might escape ordinary procedural requirements imposed state law pendency federal suit collection revenue challenged law might obstructed consequent damage state budget perhaps shift state risk taxpayer insolvency moreover federal constitutional issues likely turn questions state tax law like issues state regulatory law properly heard state courts grace brethren church supra quoting approval perez ledesma brennan concurring part dissenting part course demonstrates protecting state fisc damage part tia purpose equally shows actions throw state tax administration disarray also implicate act purpose concern preventing administrative disarray puts context explanation tia principal concern limit federal district interference collection taxes phrase context refers operation whole tax collection system implementation entire tax policy part order interfering specific collection suit disrupts one essential aspects state tax system way federal courts disrupt state tax system legislative history tax injunction act demonstrates congress worried much form relief available federal courts divesting federal courts jurisdiction interfere state tax administration grace brethen church supra decisions fair assessment real estate mcnary national private truck council oklahoma tax nptc rosewell supra make point though majority says cases support holding involved plaintiffs mounted federal litigation avoid paying state taxes ante language cases clear ignored contrary holding today fair assessment observed tia roots equity practice principles federalism recognition imperative need state administer fiscal operations last consideration principal motivating force citation omitted nptc said congress repeatedly shown aversion federal interference state tax administration passage tia one manifestation aversion summing aversion generated also principles comity federalism creating background presumption federal law generally interfere administration state taxes rosewell described act language broad prophylactic majority opinion brennan see also ibid tia passed limit interference state tax matters act designed respect administration state tax systems also state authority say state law means ederal constitutional issues likely turn questions state tax law like issues state regulatory law properly heard state courts grace brethren church supra internal quotation marks omitted see also rosewell supra establishes tia purpose solely ensure state fisc decreased diminished interest allowing state courts say state tax statutes mean act protected state fisc tia protects responsibility courts administer tax systems accountable citizens state policies decisions majority objects disagreement meaning state law case ante initial matter clear fair conclusion litigation large part turns state law requires whether product requirements violates constitution point however even controversy statutory framework arizona tax provision creates majority ruling implications far beyond case certainly result federal courts cases required interpret state tax law order complete review challenges state tax statutes heretofore consistent interpretation act legislative history prohibit interference state tax systems administration accords direct broad unqualified language statute act bars orders enjoin suspend restrain assessment tax state law effecting congressional intent give full force simple broad proscriptions statutory language tia language purpose comprehensive arguments based congressional silence question whether tia applies actions increase moneys state tax system collects moment contra winn relying dunn carey see also ante relying dunn whatever weight one gives legislative histories silence legislative record irrelevant plain congressional declaration exists matter hen terms unambiguous may speculate probabilities intention insurance ritchie wall congress said district courts barred disrupting state tax operations immaterial whether state collection raised lowered order thwart replace state chosen tax policy causes either result authority supports proposition state lacks interest reducing citizens tax burden troubling proposition proceed assumption state interest limiting tax burden citizens law provides secondary policy deserving little respect us iv final basis majority respondents rest years unexamined habit litigants courts alike resulted federal courts entertaining challenges state tax credits see ante citing representative cases reverse course unexamined practice lightly obligation give correct interpretation statute obliged maintain status quo status quo unfounded exercise federal jurisdiction establish jurisdiction see tucker truck lines bound prior exercise jurisdiction case questioned passed sub silentio respect present case different federal election nra political victory fund case presented question whether jurisdiction consider certiorari petition filed federal election commission fec solicitor general behalf fec held lacked jurisdiction see though answer seemed contradict prior practices said impressed fec argument represented several occasions past without question raised authority jurisdiction challenged none actions therefore question open one us citations omitted see also michigan dept state police never considered bound subsequent case finally brings jurisdictional issue us hagans lavine alteration original cases make clear failure consider question hardly equates thing decided contra ante stevens concurring referring prior silences courts respect tia stare decisis settled interpretation consequence follow statutory language today decision ontaxpaying associations taxpayers nontaxpayers allowed sidestep congress policy federal judicial resolution abstract state tax controversies regan concurring judgment unfortunate result deprives state courts first opportunity hear cases grant relief constitution requires foregoing reasons respect dissent footnotes state taxation purposes includes local taxation see wright miller cooper federal practice procedure pp ed local taxes imposed authority state law courts held tax injunction act applies fallon meltzer shapiro hart wechsler federal courts federal system ed purposes act local taxes uniformly held collected state law section treasury regulations assessment accomplished assessment officer signing summary record assessment supporting records provides identification taxpayer character liability assessed taxable period applicable amount assessment cfr term assessment used variety ways tax law setting word usually refers process taxing authority assigns taxable value real personal property see schoettle state local taxation law policy taxation assessment process putting value real personal property purposes tax measured percentage property values valuation ordinarily done government official assessor sometimes hire private professional actual valuations black law dictionary ed defining assessment inter alia official valuation property purposes taxation also termed tax assessment cf see also powell real property wolf ed calculate amount property taxes owed tax assessor multiplies assessed value appropriate tax rate see werner real estate law ed income taxes contrast typically anyone filed tax return unlikely forget taxpayer taxing authority first party make relevant calculation income taxes owed word however technical term irc indicates internal revenue service executes formal act assessment dissent two minds regard one hand twice suggests proper definition term assessment purposes entire plan scheme fixed upon charging taxing post hand dissent disconnect word enforcement process levy collection assessment sets motion see post congress mind challenges assessments triggering collections attempts prevent collection revenue borne final clause added whether person person tax assessed emphasis added dissent incorrectly ranks south carolina regan mcglotten tax analysts advocates post see also post latter decisions text notes seek stop collection taxes contrast south carolina regan state suit aimed reduce federal revenue receipts south carolina sought enjoin violation tenth amendment rights federal tax exemption post federal income taxation interest certain bonds held unique suit bar exercise original jurisdiction case language tia differs significantly johnson act provides part district courts shall enjoin suspend restrain operation compliance rate orders made state regulatory bodies emphasis added tia prohibit interference operation compliance state tax laws rather proscribes interference aspects state tax regimes needed produce revenue assessment levy collection petitioner urges dissent agrees tia safeguards another vital state interest authority state courts determine state law means brief petitioner post respondents however asked district interpret state law disagreement meaning rev stat ann west supp whether applied state law violates federal constitution see supra question federal courts doubt equipped adjudicate note furthermore relied upon principles comity brief petitioner preclude original jurisdiction plaintiffs sought aid order arrest countermand state tax collection see fair assessment real estate mcnary missouri taxpayers sought damages increased taxes caused alleged overassessments great lakes dredge dock huffman plaintiffs challenged louisiana unemployment compensation tax far ignor ing plain speedy efficient remedy proviso dissent charges post agree codified exception key proper understanding act statute requires state provide taxpayers swift certain remedy resist tax collections action dependent discretion example qualify fitting taxpayer remedy cf supra conflict sister circuits odds prior opinions fifth circuit aclu foundation bridges recently construed tia way director bridges involved challenge tax exemptions religious activities several louisiana statutes district line earlier fifth circuit decisions held tia apply plaintiff seeking restrain assessment levy collection state taxes eliminate allegedly unconstitutional tax exemptions reversing fifth circuit ruled tia bars federal suit seeking portion state tax system declared unconstitutional director refer four decisions lending support view purposes line drawn challenges reduce revenues attacks might augment collections see reply brief petitioner citing kraebel new york city dept housing preservation development colonial pipeline collins gillis brewers perez see also brief amicus curiae two cases taxpayers seeking relief aimed lightening tax burdens kraebel held barred taxpayer constitutional challenge exemption abatement scheme colonial pipeline held taxpayer suit seeking redistribution georgia ad valorem tax system might reduced plaintiff tax bill implicated jurisdictional bar observe broadly requested relief granted clearly conflict principle underlying tia federal courts generally avoid interfering sensitive peculiarly local concerns surrounding state taxation schemes gillis unlike kraebel colonial pipeline action declined decide hether tia actually bar availability relief noted suit seeking enhance state revenues may nonetheless fall within bar act language limited collection taxes emphasis original finally perez concerned butler act tia analog applicable puerto rico ordering dismissal case want jurisdiction rested decision statutory construction underl ying comity concerns stating order federal requiring commonwealth officials collect taxes legislature seen fit impose citizens strikes us particularly inappropriate involvement state management fiscal operations school desegregation cases last resort federal courts asserted authority direct imposition increase local tax levies even amounts exceeding ceiling set state law see missouri jenkins liddell missouri en banc cf griffin school bd prince edward controversial measure may see jenkins kennedy concurring part concurring judgment noteworthy raised cases counsel lower courts motion confirming cases order may brought federal suggest state courts second rate constitutional arbiters post instead underscore adjudications great moment discerning barrier see supra written reflecting nothing unexamined custom post unthinking habit post