In ''Frothingham v. Mellon'', 262 U.S. 447 (1923), this Court held that [[Article III]] and the [[separation of powers]] generally [[standing]] to sue based merely on plaintiff's status as a taxpayer. A narrow and [[liberal]] exception to this rule was established in ''[[Flast v. Cohen]]'', 392 U.S. 83 (1968), for [[Establishment Clause]] cases.
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In ''Frothingham v. Mellon'', 262 U.S. 447 (1923), the US Supreme Court held that a taxpayer did not have [[standing]] to sue the federal government in order to prevent particular expenditure where her only loss was an anticipated increase in taxes. The Court reasoned that the relationship between the expenditure and the anticipated tax increase was too complex and uncertain to properly determine the effect of one upon the other. Further, the Court reasoned that in accordance with the doctrine of the [[separation of powers]], it would be improper for it to review governmental expenditure in the manner sought.
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A narrow exception to the above mentioned standing rule was established in ''[[Flast v. Cohen]]'', 392 U.S. 83 (1968), for [[Establishment Clause]] cases.