that unless it's clear, kourcou are not deprived of jurisdiction. i find it hard to think that this is clear, whatever else it is. it's easy to think that it's not clear. >> well, i mean, the anti-injunction act applies not only to every tax in the code but as far as i can tell to every tax penalty in the code. >> mr. long, you said before, and i think you were quite right, that the tax injunction act is modeled on the anti-injunction act and under the tax injunction act, what can't be enjoined is an assessment for the purpose of raising revenue. tax injunction act does not apply to penalties that are designed to induce compliance with the law rather than to raise revenue. and this is not a revenue-raising measure because if it's successful, nobody will pay the penalty and there will be no revenue to raise. >> well, in bob jones the court said that they had gotten out of the business of trying to determine whether an ex action is primarily revenue raising or primarily regulatory and this one certainly raises -- is expected to raise very substantial