What is the test for a motion to dismiss a lawsuit alleging that the collection of a state tax is unconstitutional?

Plaintiffs sued in federal court, alleging that these assessment and collection procedures violate their constitutional rights. The complaint sought declaratory relief, injunctive relief, and damages pursuant to 42 U.S.C. 1983 and Conn. Gen. Stat. 52-564. The defendants moved to dismiss on the grounds that the district court lacked jurisdiction under the Tax Injunction Act ("TIA"), 28 U.S.C. 1341, and the doctrine of comity. The district court concluded that the suit was barred since it concerned the collection of a state tax. On appeal from the dismissal for lack of subject matter jurisdiction, "we review factual findings for clear error and legal conclusions de novo." Makarova v. United States, 201 F.3d 110, 113 (2d Cir. 2000).