On 26 September 2022, the US Court of Appeals for the Eleventh Circuit, issued an opinion in United States v. Meyer, 50 F.4th 23 (11th Cir. 2022), holding that the Anti-Injunction Act, codified in Code Section 7421, did not bar a defendant taxpayer from seeking a protective order in a closed suit to restrain the government from using his admissions when assessing a tax penalty in a separate administrative proceeding.

President Biden released his Administration’s budget proposal for fiscal year 2022 on 28 May 2021. To accompany the Administration’s Budget, the Treasury Department released its “General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals.