The gist of the court's holding is that "the term 'tax' in the [Anti-Injunction Act] reaches any exaction imposed by the Code and assessed by the tax collector pursuant to his general revenue authority." That definition squarely includes the penalty imposed by the minimum coverage provision, even if it is a "penalty," and even if it is not a tax for purposes of the General Welfare Clause. As a result, the AIA deprives the court of any jurisdiction to enjoin enforcement in a pre-enforcement challenge: the AIA deprives the court of subject matter jurisdiction.
Perhaps the biggest impact from this decision is that is adds substantial credence to the AIA argument, and thus will complicate matters for the Supreme Court once one of the cases gets there.
