<P> Not only the House of Representatives, but also the Senate and the judiciary have sometimes tried to guard the role of the House with regard to origination of revenue bills . For example, as early as 1789, the Senate deemed itself helpless to pass a law levying a tax . And, as mentioned, a federal court in 1915 struck down legislation contrary to the clause . The U.S. Supreme Court has expressed willingness to address such issues, according to its 1990 opinion by Justice Thurgood Marshall in Munoz - Flores: </P> <P> A law passed in violation of the Origination Clause would thus be no more immune from judicial scrutiny because it was passed by both Houses and signed by the President than would be a law passed in violation of the First Amendment . </P> <P> In 2012, the joint dissent in the U.S. Supreme Court case National Federation of Independent Business v. Sebelius mentioned that "the Constitution requires tax increases to originate in the House of Representatives" per the Origination Clause, though that issue was not addressed by the majority opinion . In 2014, Sissel v. U.S. Department of Health and Human Services, a challenge to the Affordable Care Act brought by the Pacific Legal Foundation based upon this clause, was rejected by a panel of the United States Court of Appeals for the District of Columbia, and that court later declined a request to put the matter before all of its judges ("en banc") over a lengthy dissent authored by Judge Brett Kavanaugh . </P> <P> In 2013, during the United States federal government shutdown of 2013 and the United States debt - ceiling crisis of 2013, the Republican - led House of Representatives could not agree on or pass an originating resolution to end the government crisis, as had been agreed, so the Democratic - led Senate used bill H.R. 2775 to resolve the impasse by using the Continuing Appropriations Act, 2014, an insignificant bill that originated in the House, which it amended all the tax and appropriation measures so to satisfy the formal requirements of the Originating Clause . </P>

Where does a revenue bill have to start and why