Bob Jones University filed suit to block the IRS from revoking its tax-exempt status, alleging "irreparable injury in the form of substantial federal income tax liability." In 1971, the United States District Court for the District of South Carolina granted a preliminary injunction, but in 1973 the United States Court of Appeals for the Fourth Circuit reversed that decision. The Court of Appeals relied on the Anti-Injunction Act, which states that "no suit for the purpose of restraining the assessment or collection of any tax shall be maintained in any court." A party cannot stop the government from collecting taxes. Instead, in order to protect the Government's need to assess and collect taxes efficiently, the proper procedure is for the party to pay the disputed tax and then file an action for refund.