More recently, "Bob Jones Univ. v. Simon" has been cited and considered in a suite of cases concerning the legislation of the Patient Protection and Affordable Care Act. In cases such as "Commonwealth ex rel. Cuccinelli v. Sebelius" and "Halbig v. Sebelius", injunctions against the IRS in regards to tax policies related to the Affordable Care Act were not granted by the District Courts. In the lower court rulings of "Thomas More Law Center v. Obama" and "Hobby Lobby Stores Inc. v. Sebelius", the Anti-Injunction Act was found to be not applicable in either case. In the Supreme Court case "National Federation of Independent Business v. Sebelius", the Court requested arguments to be made concerning the Anti-Injunction Act and its possible application to the Affordable Care Act by an outside attorney, as neither the government nor the plaintiffs wished to argue its potential implications. In each of these cases the Anti-Injunction Act was not applied primarily due to the use of the term 'penalties' in the language of the Affordable Care Act, which the language of the Anti-Injunction Act does not explicitly cover.