FOR WOULD-BE TRAVELLERS ON THE NONCOMPLIANT FEDERAL INCOME TAX PROTESTER PATH

Why This Is Here
     It's tempting to be apathetic about folks who follow the "noncompliant tax protester" path, but it's also sad to see people misled into doing something that is not only incorrect but also an expensive misdeed. This missive is based on an email I sent to someone who was trying to determine if the "good news" of noncompliant tax protesting was really "good news." This person was, it seemed, at least trying to do the right thing. Unfortunately, I can't say the same thing about the hucksters who market these schemes and then disappear while their "customers" take the fall. So this is for those who are so weary of taxation that they have an urge to succumb to the seemingly easy path of noncompliant tax protest, disadvantaged by having little or no tax law education or experience. There are safe and inexpensive ways to protest the federal income tax, such as getting one's self to the polls, writing letters to members of Congress and newspaper editors, organizing grass-roots campaigns, and bringing to the attention of others an understanding of who enacts the federal income tax laws and why they need to be changed. So if this saves someone the aggravation of an IRS audit (they really don't like noncompliant tax protesters), the costs of litigation, the financial ruin of penalties, or the rigors of a prison term, it was worth the effort.

TheFirst Part of the Query
      This is how the question was raised:

Specifically, I am trying to find concrete evidence that the following claims of many web sites are incorrect:

- There is no law requiring individals to pay income tax.
- The 16th amendment applies only to those in a federal jurisdiction, defined as DC, corporations and entities which deal in things like tobacco.
- "Income", according to court cases, is defined as "capital gain" as opposed to "compensation" in exchange for labor.
My Reply
      These arguments have been soundly rejected by the Tax Court and by the Courts of Appeal in numerous cases over the years, particularly in the early 80s when they proliferated in large numbers, that are collectively called "tax protester" cases. Several early cases provided detailed analyses on the "tax protester" issues that have been raised. The more recent cases cite and incorporate by reference these early cases, pulling them together into an all-encompassing overview.

      Here is an example:

Gordeon W. Beerbower v. U.S., Commissioner of Internal Revenue et al., 787 F.2d 588 (6th Cir. 1986)

* * * * * * * *

      Plaintiff claims on appeal that he is not a taxpayer subject to IRS jurisdiction, and the withholding of income tax from his wages violated fifth amendment due process, the supremacy clause, the prohibition against bills of attainder, 42 U.S.C. §§1983, 1985 and 1986, 18 U.S.C. §§241 and 242, and 5 U.S.C. §§555 and 556. He also claims that the Anti-Injunction Act is inapplicable and the award of defendants' attorneys' fees was erroneous. The district court correctly held that plaintiff's claims were without merit. Plaintiff's claim that he is not a taxpayer is unsupported and frivolous. See Martin v. Commissioner of Internal Revenue, 756 F.2d 38 (6th Cir. 1985). Wages are taxable income. Perkins v. Commissioner of Internal Revenue, 746 F.2d 1187 (6th Cir. 1984). It is well-settled that withholding income tax from wages does not violate the constiution. See Edgar v. Inland Steel Co., 744 F.2d 1276 (7th Cir. 1984); Robinson v. A & M Electric, Inc., 713 F.2d 608 (10th Cir. 1983); Stonecipher v. Bray, 653 F.2d 398 (9th Cir. 1981), cert. denied, 454 U.S. 1145 (1982). An allegation that the taxpayer's employer withheld taxes from the taxpayer's wages does not state a cause of action against either the IRS or the employer. Id. Plaintiff has also failed to state a claim under 42 U.S.C. §1983, which requires violation of civil rights under color of state law. See Edgar v. Inland Steel Co., supra; Stonecipher v. Bray, supra. His claims under sections 1985 and 1986 are without merit because allegations of racial or other class based discrimination are required to state a claim under these sections. See Griffin v. Breckenridge, 403 U.S. 88 (1971); Stonecipher v. Bray, supra. Plaintiff's claim that the IRS has discriminated against the "class" of nontaxpayers is ludicrous. 18 U.S.C. §§241 and 242, criminal counterparts to the civil rights statutes, do not provide a basis for civil liability. Aldabe v. Aldabe, 616 F.2d 1089 (9th Cir. 1980). Plaintiff's claims under 5 U.S.C. §§555 and 556 are clearly frivolous.

In fact, the courts now impose penalties for delay for those raising these arguments. See, e.g., Miller v. Commissioner, T.C. Memo 1983-476. Here is an extract from that case:

The final matter we consider is whether, in the circumstances here extant, we should, on our own motion, award damages to the United States under section 6673 n16 and, if so, in what amount. We addressed the very heart of this matter in September of 1977 in Hatfield v. Commissioner, 68 T.C. 895, 899 (1977), when we stated in clear and unequivocal language:

      In recent times, this Court has been faced with numerous cases, such as this one, which have been commenced without any legal justification but solely for the purpose of protesting the Federal tax laws. This Court has before it a large number of cases which deserve careful consideration as speedily as possible, and cases of this sort needlessly disrupt our consideration of those genuine controversies. Moreover, by filing cases of this type, the protesters add to the caseload of the Court, which has reached a record size, and such cases increase the expenses of conducting this Court and the operations of the IRS, which expenses must eventually be borne by all of us.

      Many citizens may dislike paying their fair share of taxes; everyone feels that he or she needs the money more than the Government. On the other hand, as Justice Oliver Wendell Holmes so eloquently stated: "Taxes are what we pay for civilized society". Compania de Tabacos v. Collector, 275 U.S. 87, 100 (1927). The greatness of our nation is in no small part due to the willingness of our citizens to honestly and fairly participate in our tax collection system which depends upon self-assessment. Any citizen may resort to the courts whenever he or she in good faith and with a colorable claim desires to challenge the Commissioner's determination; but that does not mean that a citizen may resort to the courts merely to vent his or her anger and attempt symbolically to throw a wrench at the system. Access to the courts depends upon a real and actual wrong--not an imagined wrong--which is susceptible of judicial resolution. General grievances against the policies of the Government, or against the tax system as a whole, are not the types of controversies to be resolved in the courts; Congress is the appropriate body to which such matters should be referred. n17

      While we did not award damages in Hatfield we issued this warning-- "* * * but if tax protesters continue to bring such frivolous cases, serious consideration should be given to imposing such damages". [Citations omitted.] Similar warnings were promulgated in Crowder v. Commissioner, T.C. Memo. 1978- 273 and Clippinger v. Commissioner, T.C. Memo. 1978-107. Tax protest petitions continued to be filed with this Court with increased frequency and, finally, upon motion of respondent, we began awarding damages to the United States in appropriate cases. See Wilkinson v. Commissioner, 71 T.C. 633 (1979) and Greenberg v. Commissioner, 73 T.C. 806 (1980) .n18 Shortly after we issued Greenberg we, for the first time, awarded damages in a proper circumstance on our own motion. Syndes v. Commissioner, 74 T.C. 864, 870-873 (1980), affd. 647 F.2d 813 (8th Cir. 1981) .n19 Petitions filed merely for delay continued to overburden this Court's docket. In recognition of this fact, on June 15, 1981, we aptly stated--

It may be appropriate to note further that this Court has been flooded with a large number of so-called tax protester cases in which thoroughly meritless issues have been raised in, at best, misguided reliance upon lofty principles. Such cases tend to disrupt the orderly conduct of serious litigation in this Court, and the issues raised therein are of the type that have been consistently decided against such protesters and their contentions often characterized as frivolous. The time has arrived when the Court should deal summarily and decisively with such cases without engaging in scholarly discussion of the issues or attempting to soothe the feelings of the petitioners by referring to the supposed "sincerity" of their wildly espoused positions. [McCoy v. Commissioner, 76 T.C. 1027, 1029-1030 (1981), affd. 696 F.2d 1234 (9th Cir. 1983).Emphasis added.]
      This Court is not the only Court that has considered awarding damages or other costs, either on its own motion or on motion of the Commissioner, in a proper case. In a tax protester situation, where one of the frivolous issues was whether the U.S. Constitution forbids taxation of compensation received for personal services, the Fifth Circuit Court of Appeals stated in late 1981--

Appellants' contentions are stale ones, long settled against them. As such they are frivolous. Bending over backwards, in indulgence of appellants' pro se status, we today forbear the sanctions of Rule 38, Fed. R. App. P. We publish this opinion as notice to future litigants that the continued advancing of these long-defunct arguments invites such sanctions, however. [Lonsdale v. Commissioner, 661 F.2d 71, 72 (5th Cir. 1981), affg. T.C. Memo. 1981-122. ]n20
In Knighten v. Commissioner, supra, the Court of Appeals following its warning took action. There, damages were not sought nor awarded in our Court. Damages were sought by the Commissioner and double costs were awarded in the Court of Appeals.

      The Court of Appeals for the Ninth Circuit has, in a summary and decisive manner, awarded double costs (under Rule 38, Fed. R. App. P.) in several tax protester cases on its own motion. On July 7, 1982, in Edwards v. Commissioner, supra at 1271, the Court said--

Meritless appeals of this nature are becoming increasingly burdensome on the federal court system. We find this appeal frivolous, Fed. R. App. P. 38, and accordingly award double costs to appellee [the Commissioner of Internal Revenue]. [Citations omitted.] [Emphasis added.] Accord, McCoy v. Commissioner, supra; Barmakian v. Commissioner, 698 F.2d 1228 (9th Cir. 1982), affg. without published opinion an unreported order and decision of this Court; Martindale v. Commissioner, supra .n21

      Here, petitioner has instituted these proceedings and has asserted as his defense to the Commissioner's determinations nothing but frivolous contentions. Petitioners with genuine controversies have been delayed while we considered this case. In these circumstances, petitioner cannot and has not shown that he, in good faith, has a colorable claim to challenge the Commissioner's determinations. Indeed, he knew when he filed his petition that he had no reasonable expectation of receiving a favorable decision. There has been no change in the legal climate and in view of the extensive and long well settled case precedents, no reasonably prudent person could have expected this Court to reverse itself in this situation .n22

      "When the costs incurred by this Court and respondent are taken into consideration, the maximum damages authorized by the statute ($500) do not begin to indemnify the United States for the expenses which petitioner's frivolous action has occasioned. Considering the waste of limited judicial and administrative resources caused by petitioner's action, even the maximumdamages authorized by Congress are wholly inadequate to compensate the United States and its other taxpayers. These costs must eventually be borne by all of the citizens who honestly and fairly participate in our tax collection system. * * *". Sydnes v. Commissioner, supra at 872-873.

      Since we conclude that this case was brought merely for delay, the maximum damages authorized by law ($500) are appropriate and will be awarded pursuant to section 6673. To reflect the foregoing

      An appropriate order and decision will be entered.

      In fact, many of these people have been sentenced to prison for failure to comply. So those taking the advice you cite are incurring a big risk. Those giving such advice, once others act thereon, are taking even a bigger risk because they often are targeted for criminal prosecution.

The Next Comment by the Inquiring Person
      The following are sites which discuss this position:

      [URLs omitted because I do not want to bring attention to these sites]

      These pages (in particular [omitted]) site various court cases, explanations of the Constitution and such, that make a very convincing argument.

My Response
      Sounding convincing and being correct are two different things.


Additional information can be found at Daniel B. Evans' THE TAX PROTESTOR FAQ Site.


Footnotes

16. Sec. 6673 provides--

"Whenever it appears to the Tax Court that proceedings before it have been instituted by the taxpayer merely for delay, damages in an amount not in excess of $500 shall be awarded to the United States by the Tax Court in its decision. Damages so awarded shall be assessed at the same time as the deficiency and shall be paid upon notice and demand from the Secretary and shall be collected as a part of the tax".
We observe that in proceedings commenced after December 31, 1982 this Court is permitted to impose damages up to $5,000 where those proceedings have been instituted or maintained by the taxpayer primarily for delay or where taxpayer's position in such proceeding is frivolous or groundless. See secs. 292(b) and (e)(2), Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97- 248, 96 Stat. 574. [Back to text]

17. The language in the first paragraph quoted above, so true when stated, is all the more impelling today because of the ever increasing caseload of this Court. [Back to text]

18. See also, Goodrich v. Commissioner, T.C. Memo. 1983-414; Cornell v. Commissioner, T.C. Memo. 1983-370; Stamper v. Commissioner, T.C. Memo. 1983-248; Sommer v. Commissioner, T.C. Memo. 1983-196, on appeal (7th Cir. July 12, 1983); Jacobs v. Commissioner, T.C. Memo. 1982-198; Senesi v. Commissioner, T.C. Memo. 1981- 723, affd. ___ F.2d ___ (6th Cir. 1983); Swann v. Commissioner, T.C. Memo. 1981-236, dismissed (9th Cir. 1981). We note that the predecessor of the statute we now consider, which in essence, contained virtually identical language, was enacted by Congress in 1926. [Back to text]

19. See also Vickers v. Commissioner, T.C. Memo. 1983-429; Mele v. Commissioner, T.C. Memo. 1983-387; Ballard v. Commissioner, T.C. Memo. 1982-56; and Graves v. Commissioner, T.C. Memo. 1981-154, affd. without published opinion 698 F.2d 1219 (6th Cir. 1982), where damages were awarded on our own motion. [Back to text]

20. Rule 38, Federal Rules of Appellate Procedure, provides--

DAMAGES FOR DELAY. If a court of appeals shall determine that an appeal is frivolous, it may award just damages and single or double costs to appellee. [Back to text]

21. In none of the four cases decided by the Ninth Circuit were damages sought or awarded in this Court. [Back to text]

22. "* * * [A] person's intent in performing an act includes not only his motive for acting (which may be defined as the objective which inspires the act), but also extends to include the consequences which he believes or has reason to believe are substantially certain to follow." Greenberg v. Commissioner, 73 T.C. 806, 814 (1980). [Back to text]

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© Copyright 1998 James Edward Maule
Permission granted to use if appropriate attribution is provided.
Last update: 24 August 1998