This decision holds that the Anti-Injunction Act (28 USC 2283) does not bar a suit to enjoin the IRS from enforcing its regulation which requires tax payers and their material advisors from filing an informational notice about micro-captive insurance programs which the IRS thinks are often used to dodge taxes without actually providing insurance.  The informational notice is not a tax and may never lead to imposition of a tax, so a suit directed solely at the notice does not seek to enjoin a tax in violation in violation of the Anti-Injunction Act.  The suit is not brought within the Anti-Injunction Act’s scope merely because failure to file the notice may lead to imposition of tax and/or criminal penalties.  And there is no other effective means of attacking the notice requirement without subjecting oneself to potential criminal punishment.