South Carolina v. Regan, Secretary of the Treasury (465 U.S. 367)
U.S. Supreme Court · decided February 22, 1984 · Supreme Court Database (Spaeth)
- Citation
- 465 U.S. 367 · 104 S. Ct. 1107
- Decided
- February 22, 1984
- Term
- October Term 1983
- Vote
- 9–0
- Majority author
- Justice Brennan
- Issue area
- Judicial Power
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice Brennan delivered the opinion of the Court. South Carolina invokes the Court’s original jurisdiction and asks leave to file a complaint against Donald T. Regan, the Secretary of the Treasury of the United States. The State seeks an injunction and other relief, on the ground that § 103(j)(l) of the Internal Revenue Code of 1954, 26 U. S. C. §103(j)(l) (1982 ed.), as added by § 310(b)(1) of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, 96 Stat. 596, is constitutionally invalid as violative of the Tenth Amendment and the doctrine of intergovernmental tax immunity. The Secretary objects to the motion on the ground that the Anti-Injunction Act, 26 U. S. C. § 7421(a), bars this action and, alternatively, that the Court should exercise its discretion to deny leave to file. We are not persuaded that either is a ground for denying the motion, and therefore grant the motion for leave to file the complaint. I — I Section 103(a) of the Internal Revenue Code (IRC) exempts from a taxpayer’s gross income the interest earned on the obligations of any State. In 1982, however, as part of TEFRA, Congress amended § 103 to restrict the types of bonds that qualify for the tax exemption granted by that section. Specifically, § 310(b)(1) of TEFRA added a new provision, §103(j)(l), to the Code. Section 103(j)(l) requires that certain obligations, termed…
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