Hancock County Land Acquisitions, LLC v. USA, 21-12508

Hancock County Land Acquisitions claimed a roughly $180 million charitable deduction for a 2016 conservation-easement donation on its Mississippi property.
The IRS opened an examination in 2018; after extensions discussions, the IRS issued a Final Partnership Administrative Adjustment (FPAA) on July 23, 2020, finding the deduction improper.
Hancock filed suit two days later alleging an APA claim that I.R.C. § 7803(e)(4) required the IRS to provide Appeals Office review before issuing the FPAA and sought injunctive and declaratory relief (including to block assessment until Appeals review).
The district court dismissed for lack of subject-matter jurisdiction, concluding the Anti-Injunction Act (AIA) and the tax exception to the Declaratory Judgment Act (DJA) barred Hancock’s requested relief.
Hancock appealed to the Eleventh Circuit, which reviewed the jurisdictional dismissal de novo and affirmed the district court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the AIA bars the suit	Suit challenges unlawful IRS procedure, not a tax assessment; CIC Services controls	Allowing relief would restrain assessment/collection because an FPAA enables immediate assessment	AIA applies; suit seeks to restrain tax assessment and is barred
Whether the Williams Packing (Enochs) exception to the AIA applies	Immediate assessment causes irreparable harm; IRS cannot ultimately prevail	Adequate legal remedy exists (Tax Court); IRS could plausibly prevail on merits	Exception does not apply; Hancock has tax-court remedy and merits are debatable
Whether declaratory relief is barred by the DJA tax exception	Declaratory relief about statutory obligations should be allowed	Tax exception is coextensive with the AIA and bars such relief	DJA tax exception bars Hancock’s requested declaratory relief

CIC Servs., LLC v. Internal Revenue Serv., 141 S. Ct. 1582 (2021) (clarifying when AIA bars suits challenging regulatory duties vs. suits that would restrain tax assessment)
Enochs v. Williams Packing & Navigation Co., 370 U.S. 1 (1962) (establishing narrow AIA injunction exception requiring irreparable harm and certainty IRS cannot prevail)
Alexander v. Americans United Inc., 416 U.S. 752 (1974) (holding the DJA tax exception is coextensive with the AIA)
In re Walter Energy, Inc., 911 F.3d 1121 (11th Cir. 2018) (AIA deprives federal courts of jurisdiction when it applies)
Bob Jones Univ. v. Simon, 416 U.S. 725 (1974) (debate on merits can foreclose application of the Williams Packing exception)