Garrison R. Armstrong v. Untied States of America

FLETCHER, Circuit Judge:

Garrison R. Armstrong appeals from the district court’s order dismissing his tax refund action. Armstrong contends that Congress violated the origination clause of the Constitution, U.S. Const, art. I, § 7, cl. 1, when it passed the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub.L. No. 97-248, 96 Stat. 324 (1982), and therefore, TEFRA is invalid. The district court rejected his claim, and we affirm.

I

BACKGROUND

In 1982 Armstrong paid a $5.18 excise tax on a commercial airline ticket. Because TEFRA increased the excise tax on domestic flights from five to…