remedy available only with respect to taxes payable to the State, would be a “plain, speedy and efficient” remedy under the statute. Noting that such a. refund would apply to less than 15% of the total taxes in controversy, the Court held that the remedy would not defeat federal jurisdiction and stated that “[a]n adequate remedy as to only a portion of the taxes in controversy does not deprive the federal court of jurisdiction over the entire controversy.” Id., at 303, and n. 11. 15 Lower federal courts have recognized that the statute codified the prior adequacy standard. See Garrett v. Bamford, 538 F. 2d, at 67 ("the decisions indicate that 'plain, speedy and efficient’ means no more than the prior equity standard of 'adequacy’ ”); Dillon v. Montana, 634 F. 2d 463, 466-467 (CA9 1980) (<HOLDING>); United Gas Pipe Line Co. v. Whitman, 595 F.
holding that under the fsia congress contemplated waivers of a specific and explicit nature recognizing that congress gave explicit sanction to preexisting equity practice and stating that the remedial certainty contemplated by  1341 is that a state forum be empowered to consider claims that a tax is unlawful and to issue adequate relief holding that to be adequate a complaint must contain a statement of facts on which a claim is based showing that the pleader is entitled to relief holding that congress necessarily contemplated that the commission would review the work of the courts and revise the guidelines holding  he who seeks equity must do equity 