RICHMOND, Va. (AP) — The federal health care overhaul survived two lawsuits dismissed Thursday on technicalities, leaving President Barack Obama's signature initiative headed toward a final resolution in the U.S. Supreme Court as early as next year.

It's possible the high court could rule on the issue by June 2012, in the midst of Obama's re-election bid.

A three-judge panel of the 4th U.S. Circuit Court of Appeals ignored the core issue of whether the law can require that individuals buy health insurance or pay a penalty starting in 2014. In the lawsuit filed by Liberty University, the court ruled that the penalty amounted to a tax — and that a tax can't be challenged before it's collected. The panel said the state of Virginia lacked legal standing to file its lawsuit.

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