1. Whether the appellate court committed
error by overturning Hibbs v. Winn, 542 U.S. 88 (2004)
by holding that any constitutional claim arising
directly from the assessment bars federal jurisdiction
even when the claim does not negatively impact the
flow of revenue to the general fund?

2. Whether the appellate court committed
error by not finding that the defendant was
collaterally estopped from asserting that the test for
exclusive jurisdiction of constitutional claims was
established in Hibbs, by virtue of their litigation in
Colemanv. Dist. of Columbia, 70 F.Supp. 3d 58 (D.D.C.
2014)?

3. Whether the appellate court committed
error by deciding the case without first resolving the
issue of collateral estoppel, where the district court
held that when a constitutional claim does not
negatively impact the flow of revenue to the general
fund, federal courts have jurisdiction? Coleman v. Dist.
of Columbia, 70 F. Supp. 3d 58 (D.D.C. 2014)

Whether the appellate court committed error by overturning Hibbs v. Winn and holding that constitutional claims arising from assessment bar federal jurisdiction even when not negatively impacting revenue flow