§ 65.016.Violation of Revenue Law

One sentence giving public prosecutors an injunctive remedy for revenue enforcement.

At the instance of the county or district attorney or the attorney general, a court by injunction may prevent, prohibit, or restrain the violation of any revenue law of this state.

Three verbs cover the range of relief — prevent a violation not yet occurring, prohibit one contemplated, restrain one under way.

"Any revenue law of this state" is broad, reaching the tax statutes generally rather than a named few.

The value of an injunction here is that it operates prospectively. Collection remedies recover tax already owed; an injunction stops the conduct producing the loss.

It is also faster than assessment and collection. A business operating outside the licensing and reporting requirements can be restrained while the tax questions are worked out.

Standing is confined to three offices — county attorney, district attorney, attorney general — so no private party may invoke the section.

That is the right limit. Revenue enforcement is a public function, and competitors complaining that a rival is evading tax would be an unmanageable class of plaintiff.

The section says nothing about the ordinary equitable requirements, and the chapter’s general provision applies — so principles of equity govern to the extent not in conflict.

Whether a public enforcement injunction requires proof of irreparable injury is precisely the kind of question that provision leaves open, and the answer generally is that a statutory enforcement remedy does not carry the private-litigant elements.