Louis Brandeis

“ Mere inconvenience to the taxpayer in raising the money with which to pay taxes is not uncommon, and is not a special circumstance which entitles one to resort to a suit for an injunction in order to test the validity or applicability of the tax. ”

“ It is urged that in order to raise the money with which to pay the State's portion of the tax, it would be necessary to readjust the tariffs of State Belt Railroad; and that the deduction of the employees' portion from the payroll would result in a multiplicity of suits by employees to recover the amounts and to reestablish their rights and privileges under the laws of the State. The meagre statements of the bill do not convince us that the apprehension alleged is well founded. ”

“ Moreover, the Board is without power to enforce its regulations except by resort to legal proceedings, as provided in Section 10 (b) 4; and in any suit which it may institute to enforce the regulations [7] ample opportunity is afforded to defend, on the ground that State Belt Railroad is not subject to the Railroad Retirement Acts. It is contended that the possible penalty, in case of a prosecution under Section 13, is so serious as to prevent the opportunity to defend from being an adequate remedy. ”