Sterling Consulting Corp. v. United States

MURPHY, Circuit Judge.

I. INTRODUCTION

This ease comes before the court on interlocutory appeal. The government appeals the district court’s assertion of jurisdiction over the determination of tax liabilities in a receivership action and the distinct court’s imposition of a deadline upon the IRS for such tax determinations. Exercising jurisdiction pursuant to 28 U.S.C. § 1292(b), this court holds the Declaratory Judgment Act prohibits the district court from determining corporate tax liabilities in a receivership action and the Anti-Injunction Act bars the district court from enjoining the IRS…