Interfirst Bank Dallas, N.A. v. United States of America, and Internal Revenue Service, Defendants

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• concluding that section 2680(c)’s exception “specifically applies to all tax-related claims”
• rejecting the plaintiff’s assertion that Congress intended section 2680(c) to bar only those suits for which adequate remedies were already available, as well as its claim that section 2680(c
• defining “levy,” as used in § 6331(b), to mean compulsion beyond the “implicit threat of audits, tax liens, and other legal sanc- tions” that prompts taxpayers to pay tax, since “few taxpayers pay taxes purely as an act of free choice”
• “[Section 2680(c)] gives no indication whatsoever that the exemption is limited to claims . . . brought by taxpayers as opposed to third parties.”
• “[Section 2680(c)] gives no indication whatsoever that the exemption is limited . . . to claims brought by taxpayers as opposed to third parties.”
• “[Section 2680(c) ] gives no indication whatsoever that the exemption is limited ... to claims brought by taxpayers as opposed to third parties.”

Source: CourtListener parenthetical corpus (CC0).