Please help me understand why it takes six (count ’em, six) attorneys from the underfunded, under stress, underpaid, IRS to defeat the motion to restrain collection and order refund made by pro se Masud M. Arjmand, Docket No. 1221-21, filed 8/22/25. Is it possible none of the six has ever encountered the Anti-Injunction Act, s/a/k/a Section 7421(a), or having encountered it, is incapable of explaining it unaided?

What is so hard about “no suit for the purpose of restraining the assessment or collection of any tax shall be maintained in any court by any person, whether or not such person is the person against whom such tax was assessed.”?  Order, at p. 3.

Masud self-reported year at issue tax due but didn’t pay with the return. IRS immediately assessed tax and add-ons and gave Masud a NITL and a couple months later (hi, Judge Holmes) a NFTL, both at no extra charge. Then IRS audited Masud’s return for year at issue, which resulted in a SND for an extra $800K plus five-and-ten substantial understatement chop. Masud petitioned that.

Meantime, the local taxing authority got a code violation judgment against Masud and tried to collect. Finding the Notice of Tax Lien, the locals “interpleaded” (did you mean “impleaded,” Judge Courtney D. (“CD”) Jones?) IRS, acknowledging that the assessed self-reported tax lien o’ercrows their judgment but that the deficiency comes behind them. IRS was then in the locals’ collection case to the extent of IRS’ claims against Masud. Clear? Thought not.

You bring an interpleader proceeding when you are confronted with conflicting claims and want the court to tell you whom to pay. You implead a newly-discovered party defendant when they may have a claim or defense against you, or may be liable with you or available for contribution if you lose, that you didn’t know about when you commenced the action or proceeding. Or so I recall from my youth on The Hill Far Above.

The exception to the Anti-Injunction Act is automatic stay arising from the petitioned notice of deficiency, per Section 6213(a). Self-reporteds can be assessed and collected summarily. Then the remedy is a CDP.

As we have both here, the only stay is on the SND and Tax Court’s jurisdiction is limited to the new amount set forth in the SND.

“Because the amounts reported on Mr. Arjmand’s return for [year at issue] were summarily assessed in accordance with section 6201(a)(1), they are not a deficiency within the meaning of section 6211(a) and are not subject to the deficiency procedures set forth in the Internal Revenue Code. See §§ 6201(a)(1), 6211(a), 6213(a), 6665(b), 7421(a); Treas Reg. §301.6211-1(a). Accordingly, there is no applicable exception to the tax anti-injunction act. The Court does not have jurisdiction over the summarily assessed amounts that Mr. Arjmand reported on his return for [year at issue], and therefore cannot restrain their collection or provide any other relief that he seeks.” Order, at p. 5.