CIC Servs., LLC v. IRS
View Official PDFBelow are plain-language sections to help you understand what the Court decided in CIC Servs., LLC v. IRS and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of CIC Servs., LLC v. IRS.
The Supreme Court decided that CIC Services, LLC's suit to enjoin IRS Notice 2016–66 is not barred by the Anti-Injunction Act, even though noncompliance may result in a tax penalty. The Court found that the suit targets the reporting requirement, not the tax penalty. The decision allows CIC's challenge to proceed without risking criminal punishment.
Holding
The single most important “bottom line” of what the Court decided in CIC Servs., LLC v. IRS.
The Court held that a suit to enjoin IRS Notice 2016–66 does not trigger the Anti-Injunction Act.
Constitutional Concepts
These are the Constitution-related themes that appear in CIC Servs., LLC v. IRS. Click a concept to see other cases that involve the same idea.
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Why Administrative Law is relevant to CIC Servs., LLC v. IRS
The case involves a challenge to an IRS notice under the Administrative Procedure Act, questioning the limits of agency authority.
Syllabus excerpt (verbatim)CIC filed a complaint challenging the Notice as invalid under the Administrative Procedure Act and asking the District Court to grant injunctive relief setting the Notice aside.
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Why Judicial Review is relevant to CIC Servs., LLC v. IRS
The Court's decision allows for judicial review of the IRS notice, determining that the Anti-Injunction Act does not bar the suit.
Syllabus excerpt (verbatim)Held: A suit to enjoin Notice 2016–66 does not trigger the Anti-Injunction Act even though a violation of the Notice may result in a tax penalty.
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Why Remedies and Relief is relevant to CIC Servs., LLC v. IRS
The case discusses the type of relief sought by CIC, focusing on setting aside the IRS notice rather than addressing the tax penalty directly.
Syllabus excerpt (verbatim)CIC's complaint seeks to set aside the Notice itself, not the tax penalty that may follow the Notice's breach.
Key Quotes
Short excerpts from the syllabus in CIC Servs., LLC v. IRS that support the summary and concepts above.
A suit to enjoin Notice 2016–66 does not trigger the Anti-Injunction Act.
CIC's suit targets the Notice, not the downstream tax penalty.
The Anti-Injunction Act imposes no bar.
