Christian Coalition of FL v. United States, No. 10-14630 (11th Cir. 2011)
Annotate this CasePlaintiff appealed the district court's dismissal of its tax refund suit for mootness. Shortly after the litigation began, the IRS refunded the disputed taxes in full. Plaintiff claimed, however, that a live controversy still existed because it also sought declaratory and injunctive relief in order to obtain a favorable determination of its tax-exempt status. Plaintiff claimed that the failure of the IRS to recognize plaintiff as a tax-exempt organization had collateral consequences that prevented the tax refund from rendering the case moot. The court held that filing a claim for a tax refund suit was not simply a procedural hurdle that, once leapt over, allowed a party to seek other forward-looking relief against the IRS after the refund had been granted. Without a live refund claim, there was no way to distinguish the case from the kind of pre-enforcement suits that Congress had expressly forbidden taxpayers from bringing. Therefore, the court affirmed the judgment of the district court.
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