so while you're right, the text in bowles and thaler are not terribly different. those cases are explained by that principle. under henderson. it doesn't apply to this case. the text in this case speaks to the suit, the cause of action of the litigant. it doesn't speak to the jurisdiction or power of the court. the anti injunction act is placed in a section of the tax code governing procedure. it's not placed in -- >> counsel, all of those -- all of that in particular -- >> you did rely on that in reid el sever. >> and we haven't relied on it in other cases. >> another consideration in reid el sever is the presence of exceptions. you said three against jurisdictional characterization. here there are 11. >> many of which themselves speak in very clear jurisdictional language. >> well, some of them have no jurisdictional language at all. and not a single one of them uses the word jurisdiction to describe the ability of the court to restrain the assessment and collection of taxes. which is what one would have expected -- >> basically, the difference of language is re

thaler rests on a special rule that applies with respect to appeals from one article iii court to another. that's -- that explains gonzalez and it explains bowles before it. you have five unanimous opinions in the last decade in which you have strongly gone the other direction on what counts as jurisdictional. >> there is an argument that we should just simply say that bowles applies only to appeals, but we haven't said that. >> no, you came very close. in henderson, justice sotomayor, you said that bowles, which is akin to thaler is explained by the special rule and understandings governing appeals from one article iii court to another. and you specifically said that it does not apply to situations involving a party seeking initial judicial review of agency action, which is what we have here. so while you're right, the text in bowles and thaler are not terribly different, those cases are explained by that principle. under henderson it doesn't apply to this case. the text in this case speaks to the suit, the cause of action of the litigant. it doesn't speak to the jurisdiction or power of

textile you're right, the in bowles and thaler are not terribly different, those cases are explained by that principle. under henderson it doesn't apply to this case. the text in this case speaks to the suit, the cause of action of the litigant. it doesn't speak to the jurisdiction or power of the court. the anti-injunction act is placed in a section of the tax code governing procedure. it's not placed in - >> counsel, all of those -all of that in particular - >> you did rely on that in reed elsevier as one consideration. >> and we haven't relied on it in other cases. >> and another -- another consideration in reed elsevier that cuts in our favor is the presence of exceptions. you said three in reed elsevier cut against jurisdictional characterization. here there are 11. and - >> many of which themselves speak in very clear jurisdictional language. >> well, some of them have no jurisdictional language at all, and not a single one of them uses the word "jurisdiction" to describe the ability of the court to restrain the assessment and collection of taxes, which is what one would have e