On January 19, 1976, the IRS revoked Bob Jones University's tax-exempt status. Subsequently, the University paid the Federal Unemployment Tax Act (FUTA) tax of $21 on one of its employees for that year in order to not come under the purview of the Anti-Injunction Act. After being denied a refund, the University proceeded to sue the IRS for revoking its tax-exempt status. The United States government filed for a counterclaim of $498,675.59 for unpaid federal unemployment taxes for the years 1971 to 1975.