Todd argued that Bob Jones University had met all the requirements of 501(c)(3) as set forth by Congress, but had its 501(c)(3) status revoked by the IRS nonetheless. Inclusion on the list of tax-exempt organizations was essential to receive donations from foundations and individuals, and Bob Jones argued that removal from this list constituted irreparable harm to the university. Todd claimed that "the lower court held that the [IRS Commissioner exceeded the statutory authority given him, that he has authority to promulgate regulations but not to change law, and that that's a matter for Congress to decide, and we of course contend that that's absolutely correct." He also argued that Bob Jones University was not seeking an injunction on the collection of taxes resulting from the loss of tax-exempt status, but rather sought only an injunction on the removal of the University from the IRS list of registered 501(c)(3)s. This argument suggested that the case "involved taxes only very remotely" and was therefore not covered by the Anti-Injunction Act, which would bar Federal Courts from preventing the collection of any taxes by the IRS. Lastly, Todd contended that revocation of tax-exempt status by the IRS was an attempt to regulate the admissions policies of private universities, and not an effort motivated by protecting tax revenue.