By Stephanie Do and Carley Roberts

The U.S. Court of Appeals for the Eleventh Circuit affirmed dismissal of a taxpayer’s complaint, arising from the Alabama Department of Revenue’s assessment and collection of state income tax, for lack of subject matter jurisdiction under the Tax Injunction Act (TIA). The court held that the TIA prohibited granting the taxpayer’s request for injunctive relief, declaratory relief and monetary awards for damages because the requested relief enjoined, suspended or restrained Alabama’s ability to assess its taxes. The court further explained that Alabama law provided “plain, speedy, and efficient” remedies for tax assessment challenges available to the taxpayer. Kelly v. Ala. Dep’t of Revenue, No. 15-12124 (11th Cir. 2016).