Appendix P: Miscellaneous Letters

        MEMO

        TO:       Trusted Colleagues

        FROM:     Mitch Modeleski, Founder
                  Account for Better Citizenship

        DATE:     November 4, 1992

        SUBJECT:  Trusts, Foreign and Domestic


             I  have   recently  taken   a  keen  interest  in  practical
        applications  of   The  Federal   Zone  to   trust  creation  and
        administration.   In particular,  I now  believe  I  have  enough
        evidence to  prove that  the correct  distinction between foreign
        and domestic  corporations is  equally applicable to trusts.  The
        purpose of  this memo is to share some of this evidence with you,
        in order  to challenge your thinking on this subject and possibly
        to open new possibilities for trust creation and administration.


             Black's Law  Dictionary, Sixth  Edition, is  a good place to
        begin.   In this  dictionary, we  find  the  following  important
        definitions:


             Foreign situs  trust.   A trust  which owes its existence to
             foreign  law.     It  is  treated  for  tax  purposes  as  a
             non-resident alien individual.
                                                         [emphasis added]

             Foreign trust.   A  trust  created  and  administered  under
             foreign law.


        Black's Law  Dictionary, Sixth  Edition, defines  "foreign state"
        very clearly, as follows:


             The several  United States***  are considered  "foreign"  to
             each other  except as  regards  their  relations  as  common
             members of the Union.
                                                         [emphasis added]


        I have  added three  asterisks ("***")  after "United  States" in
        order to  emphasize that  the "United  States"  in  this  context
        refers to the 50 States of the Union.

             Now examine  the definition  of "foreign estate or trust" in
        the definitions section of the Internal Revenue Code, as follows:


             Foreign Estate  or Trust.  -- The terms "foreign estate" and
             "foreign trust" mean an estate or trust, as the case may be,
             the income  of which, from sources without the United States
             which is  not effectively  connected with  the conduct  of a
             trade  or   business  within   the  United  States,  is  not
             includible in gross income under subtitle A.

                                                  [26 U.S.C. 7701(a)(31)]


        Do a  bit of  grammatical reconstruction,  so as to eliminate the
        references to "foreign estate", and you get the following:

             The term  "foreign trust" means a trust, the income of which
             is not  includible in  gross income  under subtitle  A.  The
             income of  a foreign trust is not includible in gross income
             when it  derives from  sources which are without the "United
             States" and  which are  not effectively  connected with  the
             conduct of a trade or business within the "United States".


             Recall the  definition of "foreign situs trust" from Black's
        supra.   Now compare  the IRC  definition of "foreign trust" with
        the IRC  definition  of  "gross  income"  for  nonresident  alien
        individuals.  Notice the component criteria of gross income for a
        nonresident alien  individual, and  their close similarity to the
        same criteria for foreign trusts:

             In the  case of a nonresident alien individual, except where
             the  context   clearly  indicates  otherwise,  gross  income
             includes only --

             (1)  gross income  which is  derived from sources within the
                  United States  and which  is not  effectively connected
                  with the  conduct of  a trade  or business  within  the
                  United States, and

             (2)  gross income  which is  effectively connected  with the
                  conduct of  a  trade  or  business  within  the  United
                  States.

                                       [26 U.S.C. 872(a), emphasis added]


        It is  crucial to remember that the term "United States", as used
        in these  sections of  the IRC, means the federal zone, i.e., the
        territory  over   which  Congress   has   exclusive   legislative
        authority.   Income which  is derived  from sources  without  the
        "United States"  is not  included in gross income for nonresident
        aliens.  Likewise, income which is effectively connected with the
        conduct of a trade or business without the "United States" is not
        included in  gross income  for nonresident  aliens.  Therefore, I
        have proven  that the following rule has identical application to
        nonresident aliens and foreign trusts:

             Income is  excludible from the computation of "gross income"
             if it  derives from  sources which  are without  the "United
             States" and  which are  not effectively  connected with  the
             conduct of a trade or business within the "United States".

             Now, let's dig a little deeper in order to determine if this
        finding is  supported by  other sections  of the  IRC.   Find the
        heading "foreign  trusts" in  the Topical  Index of  the  IRC  as
        published by  Commerce Clearing  House.    There  you  will  find
        references to  "situs" at  402(c)  and  404(a)(4).    Read  these
        sections carefully:

             Taxability of  Beneficiary of  Certain Foreign Situs Trusts.
             --   For purposes of subsections (a) and (b), a stock bonus,
             pension, or  profit-sharing trust  which would  qualify  for
             exemption from  tax under section 501(a) except for the fact
             that it  is a  trust created or organized outside the United
             States shall  be treated  as if  it were a trust exempt from
             tax under section 501(a).

                                       [26 U.S.C. 402(c), emphasis added]

             Trusts Created  or Organized  Outside the  United States. --
             If a  stock bonus,  pension, or  profit-sharing trust  would
             qualify for  exemption under  section 501(a)  except for the
             fact that  it is  a trust  created or  organized outside the
             United States,  contributions to such a trust by an employer
             which is  a resident, or corporation, or other entity of the
             United States,  shall  be  deductible  under  the  preceding
             paragraphs.
                                    [26 U.S.C. 404(a)(4), emphasis added]

        It is  a well established principle of law that the 50 States are
        "foreign" with respect to each other, just as the federal zone is
        "foreign" with  respect to  each of them (In re Merriam's Estate,
        36 NE  505 (1894)).   The  status of being foreign is the same as
        "belonging to"  or being  "attached to"  another state or another
        jurisdiction.   The proper  legal distinction  between the  terms
        "foreign" and  "domestic" is  best seen in Black's definitions of
        foreign and domestic corporations, as follows:


             Foreign corporation.   A  corporation doing  business in one
             state though chartered or incorporated in another state is a
             foreign corporation  as to the first state, and, as such, is
             required to  consent to  certain conditions and restrictions
             in order to do business in such first state.


             Domestic corporation.   When  a corporation is organized and
             chartered in a particular state, it is considered a domestic
             corporation of that state.

                                                         [emphasis added]

             In light of all the above, I now contend that untold numbers
        of trusts  have been  created on  the basis of a belief that they
        are domestic  trusts when,  in fact,  they are foreign trusts, as
        the terms  "domestic" and "foreign" are defined in the IRC and in
        the law  dictionaries.   The Internal  Revenue Code  was  written
        under authority granted to Congress for the exercise of exclusive
        legislative jurisdiction over the federal zone.  Accordingly, the
        50 States  and their  respective laws  are actually  foreign with
        respect to  the federal  zone.   The 10th Amendment makes it very
        clear that powers not specifically delegated to the United States
        by  the  Constitution,  nor  prohibited  to  the  States  by  the
        Constitution, are  reserved to  the States  or to  the people.  A
        common-law trust  situated in  California exercises  rights which
        are reserved  to the  people, because  California is a common-law
        State and  because the  U.S. Constitution  specifically  reserves
        such rights to the people.




                                           c/o P. O. Box 6189
                                           San Rafael
                                           California Republic
                                           Postal Code 94903-0189/TDC

                                           February 15, 1993


        Dagny Sharon
        Attorney-at-Law
        c/o 17332 Irvine Boulevard, #230
        Tustin, California Republic
        Postal Code 92680/tdc

        Dear Dagny:

             I appreciated  the opportunity  to make your acquaintance at
        the Libertarian  Party Convention in Sunnyvale this past weekend.
        I also  regret that  we didn't  have a  chance to spend more time
        together.  Your videotape is quite original and light-hearted;  I
        hope it brings you much success.

             Had we  found a  way to  spend more  time talking  with each
        other, there  is one  important matter  which I  would definitely
        have  wanted   you  to  consider  more  carefully.    During  our
        conversation in  the bar,  while I  was eating lunch, you implied
        that one  of your  goals is  to work  towards a  "democracy"  for
        America.   Whether you  intended it  this way or not, such a goal
        directly contradicts Article 4, Section 4 of the Constitution for
        the United States of America, to wit:


             Section 4.  The United States shall guarantee to every State
             in this Union a Republican Form of Government ....


             What exactly  is a  "Republican Form"  of government?  It is
        one in  which the  powers of sovereignty are vested in the people
        and exercised  by the  people.   Black's  Law  Dictionary,  Sixth
        Edition, makes this very clear:


             Republican government.   One  in   which   the   powers   of
             sovereignty are  vested in  the people  and are exercised by
             the people,  either  directly,  or  through  representatives
             chosen by  the people,  to whom  those powers  are specially
             delegated.   In re  Duncan, 139  U.S. 449,  11 S.Ct. 573, 35
             L.Ed. 219;   Minor v. Happersett, 88 U.S. (21 Wall.) 162, 22
             L.Ed. 627.


             Both  the   California  State   Constitution  and  the  U.S.
        Constitution state  that the  latter shall  be the supreme Law of
        the land.  In the U.S. Constitution, Article 6, Clause 2 states:

             This Constitution,  and the  Laws of the United States which
             shall be  made in Pursuance thereof;  and all Treaties made,
             or which  shall be  made, under  the Authority of the United
             States, shall  be the  supreme Law  of the  Land;   and  the
             Judges in  every State  shall be bound thereby, any Thing in
             the Constitution  or Laws  of  any  State  to  the  Contrary
             notwithstanding.


             At the  turn of the century, the U.S. Supreme Court issued a
        series of  controversial cases  now known  as The  Insular Cases.
        These cases  were predicated,  in part, on the principle that the
        Constitution for the United States as such does not extend beyond
        the boundaries  of the  States which  are united by and under it.
        Accordingly, this  principle  set  a  crucial  precedent  whereby
        Congress was free to establish a legislative democracy within the
        federal zone, instead of a constitutional republic.

             The federal  zone is  the area over which Congress exercises
        exclusive legislative  jurisdiction;  it encompasses the District
        of Columbia  and such areas as Guam and the Virgin Islands.  Even
        more important  is  the  fact  that  this  exclusive  legislative
        jurisdiction extends  to all  persons  who  are  subject  to  it,
        regardless of  where they  may reside.   As  such, the  status of
        "citizen of  the United  States" (also  known as  "U.S. citizen")
        causes one to be subject to the letter of all municipal statutes,
        rules and  regulations which Congress enacts under this exclusive
        legislative authority.   The  constitutional definition  of  this
        second class  of citizens  is alleged  to be  the so-called  14th
        Amendment.   However, two  standing decisions of the Utah Supreme
        Court have  struck  down  the  ratification  of  this  amendment.
        Coupled with all the evidence which that Court utilized to arrive
        at these  decisions, we  have therein good cause to conclude that
        the so-called  14th Amendment  is null  and void  for  fraud  and
        duress.   My book  The Federal  Zone discusses the so-called 14th
        Amendment as follows:

             Not only  did this  so-called "amendment"  fail  to  specify
             which meaning  of the  term "United  States" was being used;
             like the 16th Amendment, it also failed to be ratified, this
             time by  15 of  the 37  States which  existed in  1868.  The
             House Congressional  Record for  June 13, 1967, contains all
             the documentation  you need to prove that the so-called 14th
             Amendment was  never ratified  into law  (see page  15641 et
             seq.).   For example,  it itemizes  all States  which  voted
             against the  proposed amendment,  and the precise dates when
             their Legislatures  did so.   "I  cannot  believe  that  any
             court, in  full possession  of its faculties, could honestly
             hold that  the amendment was properly approved and adopted."
             State vs  Phillips, 540  P.2d. 936,  941 (1975).   The  Utah
             Supreme Court  has detailed  the shocking and sordid history
             of the  14th Amendment's  "adoption" in the case of Dyett vs
             Turner, 439 P.2d 266, 272 (1968).


             With this background knowledge firmly in hand, it is easy to
        explain why  the federal  government would reiterate the theme of
        "democracy" and  "democratic institutions"  over and  over in its
        media propaganda.   It  is now  obvious that such programming has
        been entirely  successful;    witness  the  large  percentage  of
        "Libertarians" who  make repeated  reference to  their  political
        goal of  "democracy" for  America.   Perhaps without  knowing it,
        they are  participating in  the slow  but steady  demise  of  the
        nation symbolized  by the  Stars and  Stripes, "the  Republic for
        which it stands, one Nation, under God, indivisible, with liberty
        and justice  for all."   The  Insular Cases  made it possible for
        America to  become divisible into a constitutional republic and a
        legislative democracy.    It  is  the  strategy  of  "divide  and
        conquer", being  applied once  again with much success, this time
        to our very own homeland.

             I hope I have given you a few things to think about.


        Sincerely yours,




        /s/ Mitch Modeleski, Founder
        Account for Better Citizenship

        enclosures:  People vs Boxer pleadings
                     "Citizen is a Term of Municipal Law"

        copy:  Jerry Collette



                                           c/o P. O. Box 6189
                                           San Rafael
                                           California Republic
                                           Postal Code 94903-0189/TDC
        
                                           February 7, 1993
        John Voss, Director
        N.C.B.A.
        c/o P.O. Box 2255
        Longmont, Colorado
        Postal Code 80502/tdc
        
        Dear John:
        
             Thanks so  much for  all the  materials which  you  recently
        sent,  with  a  copy  of  your  letter  to  Mitch  Beals.    Time
        permitting, I  do intend to do a thorough analysis of the written
        opinions.   I am  very disappointed,  but not surprised, that the
        appellate decisions  were "not  for publication".  I took all the
        decisions to  the law  library yesterday,  but simply  ran out of
        time.  Enclosed are the preliminary results of that one afternoon
        at the  library.   Nevertheless, a  distinct pattern  is emerging
        already.
        
        
        Item #1:   28  U.S.C. 297.  Assignment of judges to courts of the
                  freely associated compact states
        
             This  statute   was  part  of  the  comprehensive  "Judicial
        Improvements Act" submitted to  Congress by Peter F. Rodino, Jr.,
        Chairman, Committee  on the  Judiciary, House of Representatives.
        It went  into law  on  November  19,  1988  (P.L.  100-702,  copy
        attached).   Notice that  subsection (a)  refers to  "the  freely
        associated compact  states" and  to "the  laws of  the respective
        compact state".   In  and of  themselves,  these  references  are
        significant because  I was  unable to  find any discussion of the
        legislative history  for this  specific statute;    the  material
        cited in U.S. Code Cong. and Adm. News skipped any mention of it.
        The statute  is  also  too  recent  for  any  case  law  to  have
        developed, and  much too  recent for  the term "freely associated
        compact states"  to appear  in Words  and Phrases,  C.J.S., or Am
        Jur, although  "compact" has  several  meanings  in  Black's  Law
        Dictionary.
        
             What makes  this term even more significant is the reference
        to it that is found in subsection (b), to wit:
        
        
             The Congress  consents the  acceptance and  retention by any
             judge so  authorized of  reimbursement  from  the  countries
             referred to in subsection (a) ....
                                                                         
                                                         [emphasis added]
        
        I am going on memory now, but I do seem to recall a key exception
        to the  definition of  "state" once  found  in  Title  28.    The
        exception was to another provision of Title 28 which utilized the
        term "State  court".   I think  this  exception  has  since  been
        removed by  subsequent amendment,  but the  pre-amendment version
        clearly implied  that the  meaning of  "state" as  found  in  the
        standard definition  was different from the meaning of "state" as
        intended by  the term  "State court"  (hence  the  need  for  the
        "exception" clause).   Therefore, the standard definition implied
        a federal state, not a Union State.
        
             In section 297 supra, we are faced with a choice between two
        conflicting and mutually incompatible interpretations of the term
        "freely associated  compact states".   If  these states are Union
        States, then  the "compact" may well be the U.S. Constitution and
        Congress has admitted openly that Union States are the "countries
        referred to  in subsection  (a)".   If  these  states  are  other
        nations in  the family  of nations  (e.g. China, Japan), then the
        "countries"  referred  to  in  subsection  (a)  are  these  other
        nations, and  I can  only speculate  about the "compact" to which
        Section 297  refers.  Could it be the U.N. charter?  If not, what
        else could  it be?  some international treaty?  I wonder if there
        is a  way to  inquire of  the House  Judiciary Committee  without
        tipping our  own hands  and giving  the  Committee  a  reason  to
        obfuscate the  real answer.    Or,  what  about  the  Library  of
        Congress, or  Congressional Research Service?  I wouldn't put too
        much faith  into the  CRS, in light of the hack job they continue
        to do on "Frequently Asked Questions about Federal Income Taxes".
        
             This little  tidbit is highly significant when placed in the
        larger context  of  all  the  research  now  assembled  into  the
        electronic version  of The  Federal  Zone,  third  edition  (disk
        enclosed).   In particular,  my interpretation of the distinction
        between "foreign"  and  "domestic"  is  amply  supported  by  the
        definitions in  Black's Sixth  Edition,  and  especially  by  the
        Supreme Court decision to uphold the New York Court's decision of
        In re Merriam's Estate, 36 NE 505 (1894).  Black's definitions of
        foreign and  domestic corporations,  in my  opinion, leave little
        room for  doubt about  the correct  distinction  here.    Black's
        defines "foreign state" very clearly, as follows:
        
        
             The several  United States***  are considered  "foreign"  to
             each other  except as  regards  their  relations  as  common
             members of  the Union.  ... [O]ne  state  of  the  Union  is
             foreign to another.
                                                         [emphasis added]
        
        Item #2:  U.S. Code Service, Lawyers Edition, Interpretive Notes
        
             In light  of the  pivotal  importance  of  this  distinction
        between "foreign"  and "domestic",  it was  revealing to discover
        the nearly  total absence  of case  law on  this question  in the
        U.S.C.S. Lawyers  Edition (where  you would  expect a plethora of
        citations).   In the  main body  of U.S.C.S. dealing with the IRC
        definitions in  7701, there  is only  one reference  to  "foreign
        estate" (a  revenue ruling)  and there are only two references to
        "domestic building  and loan association" (a revenue ruling and a
        district court  ruling).  What is even more revealing is the case
        of U.S.  vs Bardina,  the one  and   only  citation  to  the  IRC
        definition of "United States", to wit:
        
        
             Even though  26 USCS  7701(a)(9) defines  "United States" as
             including only  United  States  and  District  of  Columbia,
             Puerto Rico  is considered as being within United States for
             purposes of  6-year statute  of limitations  on tax  crimes;
             ....
                                                         [emphasis added]
        
        
        Notice the  blatant tautology  (again).   Notice also  that  this
        interpretation flatly contradicts the actual IRC definition:
        
        
             (9)  United States. -- The term "United States" when used in
             a geographical  sense  includes  only  the  States  and  the
             District of Columbia.
                                   [26 U.S.C. 7701(a)(9), emphasis added]
                                                                         
                                                                         
        The term  "States"  is  very  different  from  the  term  "United
        States".  And, of course, the corresponding definition of "State"
        makes absolutely no mention of any Union States:
        
        
             (10)   State. --  The term  "State" shall  be  construed  to
             include the District of Columbia, where such construction is
             necessary to carry out provisions of this title.
                                                                         
                                                  [26 U.S.C. 7701(a)(10)]
                                                                         
                                                                         
             Moving on  to the  Cumulative Supplement  for  the  U.S.C.S.
        Lawyers Edition,  we find  a similar  pattern.  Here, we find one
        revenue ruling  concerning a "foreign estate", and four citations
        to "resident and nonresident alien", two of which are "TC Memos",
        one of  which is a "Private Letter Ruling", and one of which is a
        "Revenue Ruling".   These  are not  exactly sterling authorities!
        One of  these citations  concerned a former official of a foreign
        government that  was overthrown  while  he  was  in  the  "United
        States" under  diplomatic passport.    Another  concerned  a  "US
        citizen who  obtained a  US passport  before moving  to a foreign
        country".  Another concerned a spouse's election to be treated as
        a resident  alien under  IRC 7701(b).  The last citation is worth
        investigating:
        
             Status of trust as foreign trust turns upon whether trust is
             comparable  to   nonresident  alien   individual;      trust
             established and  administered under  laws of foreign country
             whose trustee  is a  foreign  entity  and  whose  corpus  is
             located in a foreign country is nonforeign trust even though
             trust is  grantor trust and its income is taxable to grantor
             who is United States citizen.  Rev Rul 87-61, 1987-2 CB 219.
        
                                                         [emphasis added]
        
             It would be revealing to examine the details about the trust
        in question,  i.e., what was the "foreign country" under the laws
        of which the trust was established and administered.  If it was a
        Union State,  we have  a bingo.   Who  or what  was the  "foreign
        entity" trustee?  Where exactly was the "corpus" located?  Notice
        the term "nonforeign";  I presume this means "domestic", based on
        the  IRC   definition  of  "foreign"  at  7701(a)(5)  (i.e.,  not
        domestic).   Finally, notice  that there  is a "grantor" who is a
        "United States  citizen";   this status  appears to  be the  only
        mention of any nexus with the federal zone (if any).
        
        
        Item #3:  United States Code Annotated (U.S.C.A.)
        
             Again, an  identical  pattern  is  found  in  the  annotated
        version of  the United  States  Codes.    Here,  we  do  find  an
        interesting exception  to the  general rule for the federal zone,
        i.e., a  Guam corporation  is "foreign"  for federal  income  tax
        purposes:
        
             Guam is  not a  "territory" within  meaning of  this section
             defining domestic corporation as one created or organized in
             United States or under laws of United States or of any state
             or territory,  and Guam  is considered  a possession so that
             its  corporations   are  foreign   for  federal  income  tax
             purposes.  Sayre & Co. vs Riddell, C.A. Guam, 1968, 395 F.2d
             407.
        
        
             Notice  how  carefully  they  skirt  the  general  issue  of
        exclusive legislative  jurisdiction by  ruling  that  Guam  is  a
        "possession", and  "possessions" were  not mentioned in the IRC's
        definition of "domestic" at that time ("or Territory" was deleted
        in 1977).   In  other words, in 1968 the definition of "domestic"
        mentioned "United  States", and  "any State or Territory".  Since
        Guam was  found to be a "possession" and not the "United States",
        not a  "State" and  not a  "Territory", it  was not  domestic and
        therefore foreign.   This  is a  fascinating little  intricacy in
        this semantic jungle.
        
             The only  other citation  of any  interest is  the 1944 case
        which interpreted  the meaning  of "includes".   I  consider this
        decision to  be erroneous,  for reasons which I explain in detail
        in Chapter  12 of The Federal Zone, third edition.  Specifically,
        in formal  English, a  noun is  either a  person, a  place, or  a
        thing.   The IRC specifically defines a trust to be a "person" as
        opposed to  a "place"  or a  "thing" (see  IRC 7701(a)(1)).   The
        clarification of  "includes" at  IRC 7701(c)  specifically states
        that this  term shall  not be  deemed  to  exclude  other  things
        otherwise within  the meaning  of  term  defined;    notice  that
        "persons"  and   "places"  are  conspicuously  absent  from  this
        clarification of  "includes".   Therefore, a  "trust" cannot be a
        thing otherwise  within the  definition of "transferee" because a
        trust is  a person,  by definition,  and a  "transferee" is not a
        person because  it is  not mentioned  in the  IRC  definition  of
        "person".  I know this may sound strained, but the IRC definition
        of "person" clearly embraces only an individual, a trust, estate,
        partnership, association,  company  or  corporation;    moreover,
        there is ample evidence that the IRC does obey strictly the rules
        of formal English grammar.
        
        
             That's it!   Now,  don't you  get the feeling, as I do, that
        they are  trying their  best to  avoid these crucial distinctions
        between "foreign"  and "domestic"?  In light of the clarity which
        is  found   in  Black's   definitions  of  foreign  and  domestic
        corporations, I  would be hard pressed to demonstrate a clear and
        consistent pattern  among these sparse authorities, many of which
        are not even courts.  John, I am forced to conclude that some (if
        not all)  of these  cases were contrived, and that a thorough set
        of consistent  Court authorities  is  very  conspicuous  for  its
        absence.
        
        
        Item #4:  McKinley vs United States of America, S.D. Ohio, 1992
        
             Time  permitting,   I  will  try  my  best  to  analyze  the
        unpublished cases  which you generously provided to me.  For now,
        I will  take  a  brief  look  at  McKinley  because  it  will  be
        published, and  because there is so little in this decision which
        is relevant to The Federal Zone, i.e.:
        
        
             The Court  takes  judicial  notice  that  while  Ohio  is  a
             sovereign state,  it is  nevertheless  part  of  the  United
             States and  Ohio residents  are also residents of the United
             States and  are subject  to taxation.   The  Court finds the
             plaintiffs to be residents of the United States and not non-
             resident aliens.
                                                         [emphasis added]
                                                                         
             I  guess   this  Court   failed  to   read  Hooven   or  the
        corresponding definitions  of "United  States" in  Black's.  More
        importantly, this  decision flatly  contradicts the definition of
        "United States"  at IRC  7701(a)(9).   Sure, Ohio  is part of the
        "United States"  if "United  States" means  the several States of
        the Union.  However, the IRC says that "United States" (when used
        in a  geographical sense)  includes only the District of Columbia
        and the  States, and  "State" shall  be construed  to include the
        District of  Columbia (and  nothing else)!   Since  singular  and
        plural are  interchangeable (per Title 1), since "include" is not
        found in  the clarification  of  "includes"  and  "including"  at
        7701(c),  and  since  7701(c)  mentions  only  "things"  and  not
        "persons" or  "places", we are entirely justified in arguing that
        the term  "United States"  at 7701(a)(9) omits any mention of the
        Union States because they were intended to be omitted.  The rules
        of statutory  construction support  this  inference,  as  do  the
        changes to  7701(a)(9) &  (10) that  resulted from the Alaska and
        Hawaii Omnibus Acts:  Alaska and Hawaii were removed from the IRC
        definition of  "State" when  they joined  the  Union  (of  freely
        associated compact  states).   So,  as  pro  bono  judge  of  the
        Sovereign Electrical  Circuit of  Justice, I  hereby reverse  the
        holding in  McKinley vs  United States of America and remand with
        instructions to  take explicit judicial notice of the legislative
        history of  IRC 7701(a)(9),  in addition  to the well established
        rules of statutory construction (see Sutherland, for example).
        
        
        Item #5:  Notes on Decisions re: 1:6:2 and Null and Void Lloyd
        
             These cases are either favorable or neutral.  Lloyd, you are
        a sitting  duck.  Notice also the careful IRC distinction between
        "Secretary of  the Treasury"  and "Secretary" at 7701(a)(11).  At
        first glance, this is bad news for our 7401 challenge, but closer
        examination reveals the following:
        
        
             (A)  In General. -- The term "or his delegate" --
        
             (i)  when used  with  reference  to  the  Secretary  of  the
                  Treasury, means any officer, employee, or agency of the
                  Treasury Department duly authorized by the Secretary of
                  the Treasury  directly, or  indirectly by  one or  more
                  redelegations of  authority, to  perform  the  function
                  mentioned or described in the context;
        
        
             Even though  IRC 7401  utilizes the  term "Secretary", which
        means the Secretary of the Treasury or his delegate, the term "or
        his  delegate"   means  an   officer,  employee  or  agency  duly
        authorized by  the Secretary  of the Treasury either directly, or
        indirectly by  one or  more redelegations of authority.  In other
        words, Lloyd  Bentsen must  be in  the loop,  either directly, or
        indirectly by  one or  more redelegations  of authority.   So, it
        looks as if Null and Void Lloyd remains in a heap'a trouble;  his
        colorable acts will spread through the Treasury Department like a
        computer virus,  infecting everything  they touch.  We should get
        an expert  on delegation  of  authority  to  see  what,  if  any,
        redelegations originated  from Nicholas  Brady and  whether  they
        remain valid and in force after Bentsen's reign began.
        
        
             Enough for now.  I know you have nothing else to do but read
        these technicalities.  The devil is always in the details.
        
        Sincerely yours,
        
        
        
        
        /s/ Mitch Modeleski, Founder
        Account for Better Citizenship
        
        enclosures
        
        copy:  Mitchell Beals
               (great first name)
        
        


        
                                           c/o P. O. Box 6189
                                           San Rafael
                                           California Republic
                                           Postal Code 94903-0189/TDC
        
                                           February 8, 1993
        John Voss, Director
        N.C.B.A.
        c/o P.O. Box 2255
        Longmont, Colorado
        Postal Code 80502/tdc
        
        Dear John:
        
             In my  letter to you of February 7, my memory failed me when
        I referred to Title 28;  the correct reference was Title 8 (I got
        one number right).  I tracked it down today for you, because I am
        convinced that  one of the "unpublished" cases which you recently
        sent to  me is  completely wrong for ruling that Union States are
        not "foreign  countries" for  purposes of  the IRC.   Enclosed is
        stunning proof  of my  position from  American Jurisprudence.   I
        picked  up  the  trail  in  Ballentine's  Law  Dictionary,  Third
        Edition, where it defines "sovereign state" as follows:
        
             In the  United States, each state constitutes a discrete and
             independent sovereignty,  and consequently  the laws  of one
             state do  not operate of their own force in any other state.
             16 AmJur J2d, "Conflict of Laws", Section 4.
        
                             [Ballentine's Law Dictionary, Third Edition]
        
             I had to go hunting for the corresponding section in Am Jur,
        because the  reference to  Section 4 is a typographical error.  I
        found what I was looking for at Section 2 instead.  The key is to
        understand that  the IRC  is a  "municipal law"  as far as income
        taxation is concerned (see Conclusions in The Federal Zone):
        
             "... [T]he several states ... are otherwise, at least so far
             as private  international law  is  concerned,  in  the  same
             relation as  foreign countries13.   The  great  majority  of
             questions of private international law are therefore subject
             to the  same rules when they arise between two states of the
             Union as when they arise between two foreign countries,  and
        
                                                          [continued ...]
        
        
        ____________________
        
        Footnotes:
        
        13.  Hanley vs Donoghue, 116 U.S. 1, 29 L.Ed 535, 6 S.Ct 242
             Stewart vs Thomson, 97 Ky 575
             Emery vs Berry, 28 NH 473
        
             in the  ensuing  pages  the  words  "state,"  "nation,"  and
             "country" are  used synonymously  and interchangeably, there
             being no intention to distinguish between the several states
             of the  Union and  foreign countries  by the  use of varying
             terminology.
        
                            [16 Am Jur 2d, "Conflict of Laws", Section 2]
        
        Notice, in particular, the comment in footnote 11:
        
             In the sense of public international law, the several states
             of the  Union are  neither foreign  to the United States nor
             are they  foreign to each other, but such is not the case in
             the field of private international law.  Robinson vs Norato,
             71 RI 256, 43 A2d 467, 162 ALR 362.
        
        Not to  be outdone,  Black's Sixth  Edition chimed  in  with  the
        following similar message:
        
             The term "foreign state," as used in a statement of the rule
             that the  laws of  foreign nations  should be  proved  in  a
             certain manner,  should be construed to mean all nations and
             states other  than that in which the action is brought;  and
             hence one  state of  the Union is foreign to another, in the
             sense of that rule.
        
                                  [Black's Law Dictionary, Sixth Edition]
        
             Further stunning  proof of  The Federal Zone thesis is found
        in the  Immigration and  Nationality Act  (see  attached),  where
        Congress slipped  by including  a key  exception in its statutory
        definition of  "State"  at  8  USC  1101(a)(36).    Prior  to  an
        amendment in 1987, this definition included the language "(except
        as  used   in  section  310(a)  of  title  III  [8  USCS  Section
        1421(a)])".  At that time, Section 1421(a) of Title 8 referred to
        courts "in any State" and "all courts of record in any State".  I
        failed to  pull the  current text  of 1421(a),  but  the  current
        1101(a)(36) removed  the exception  clause!   I  would  bet  that
        1421(a) now  has a  special  definition  for  the  term  "State",
        because 1421(a) must be talking about courts of the Union States.
        For corroboration,  I have  enclosed a  page from  the California
        State Constitution (1879), wherein California Superior Courts are
        given clear  original jurisdiction  to naturalize  and "to  issue
        papers therefor".
        
        Sincerely yours,
        
        
        
        /s/ Mitch Modeleski, Founder
        Account for Better Citizenship
        enclosures:  photocopies of evidence
        




                                           c/o P. O. Box 6189
                                           San Rafael
                                           California Republic
                                           Postal Code 94903-0189/TDC
        
                                           February 1, 1993
        Rich Pralle, CFS
        R D P & Associates
        100 Brush Creek Road, #105
        Santa Rosa, California Republic
        Postal Code 95404/tdc
        
        Dear Rich:
        
             I may  have misunderstood something which you said about the
        Internal Revenue  Code.  Am I correct in remembering you say that
        IRC 6672 concerned "withholding agents"?  When I returned home, I
        looked up this section:
        
             Section 6672.  Failure to Collect and Pay Over Tax,
                            or Attempt to Evade or Defeat Tax
        
             (a)  General  Rule.  --  Any  person  required  to  collect,
             truthfully account for, and pay over any tax imposed by this
             title who willfully fails to collect such tax, or truthfully
             account for  and pay over such tax, or willfully attempts in
             any manner  to evade  or defeat  any such tax or the payment
             thereof, shall,  in addition  to other penalties provided by
             law, be liable to a penalty equal to the total amount of the
             tax evaded,  or not collected, or not accounted for and paid
             over.   No penalty  shall be  imposed under  section 6653 or
             part II  of subchapter  A of  chapter 68  for any offense to
             which this section is applicable.
        
                                         [26 U.S.C. 6672, emphasis added]
        
        As you  can see,  there is  no explicit  mention of  "withholding
        agents" in IRC 6672.  The section to which I was referring in our
        conversation was IRC 7701(a)(16):
        
             (16)   Withholding Agent.  -- The  term "withholding  agent"
             means any  person required  to deduct  and withhold  any tax
             under the provisions of section 1441, 1442, 1443, or 1461.
        
                                  [26 U.S.C. 7701(a)(16), emphasis added]
        
             Sections 1441, 1442 and 1443 are too long to reproduce here.
        Their headings provide some indication of their contents:
        
             Section 1441.  Withholding of Tax on Nonresident Aliens
        
             Section 1442.  Withholding of Tax on Foreign Corporations
        
             Section 1443.  Foreign Tax-Exempt Organizations
        
             The following  is the entire text of IRC 1461.  This section
        is important  because it  specifically makes "withholding agents"
        liable for the taxes they deduct and withhold:
        
             Section 1461.  Liability for Withheld Tax
        
             Every person  required to  deduct and withhold any tax under
             this chapter  is hereby  made liable  for such  tax  and  is
             hereby indemnified  against the  claims and  demands of  any
             person for  the amount  of any  payments made  in accordance
             with the provisions of this chapter.
        
                                         [26 U.S.C. 1461, emphasis added]
                                                                         
             In other  words, the persons from whom they withhold are not
        liable for  the taxes  which they  withhold.   That  is  to  say,
        nonresident aliens are not liable for the taxes that are withheld
        from the  dividends they  receive from  stock issued  by domestic
        corporations (see Treasury Decision 2313).
        
             So, we can link 1461 and 6672 because withholding agents are
        liable for  the taxes  they deduct  and withhold,  i.e., they are
        required to  collect  and  pay  over  the  tax  imposed  by  1461
        (combining the language of 6672 and 1461);  if they don't pay the
        taxes they  deduct and withhold, then they would be liable to the
        penalty defined in 6672.
        
             Our research  indicates that  "withholding agents"  are  the
        only ones  who are  specifically made  liable by  the IRC for the
        payment of  income taxes.   If  you can  find another IRC section
        which specifically  makes anyone  else liable  for the payment of
        income taxes,  I would appreciate getting the exact citation from
        you.
        
             On another subject, I have several serious problems with the
        T.A.G. flyer  entitled "Are You Really Liable?"  One excerpt from
        this flyer reads:
        
             Section 7701(a)(1) defines the term person as:
        
                  "The term  'person' shall  be  construed  to  mean  and
                  include an  individual, a  trust, estate,  partnership,
                  association, company or corporation."
        
             Well now,  that certainly  seems  easy  enough  and  section
             7701(a)(1) makes  no mention  of the term "U.S. Individual".
             Now, look at section 7701(a)(30):
        
                  "The term 'United States person' means -
                  (A)  a citizen or resident of the United States,
                  (B)  a domestic partnership,
                  (C)  a domestic corporation, and
                  (D)  any estate or trust ...."
        
             There  is   no  mention   of  the   term   "U.S.   Citizen";
             "Individual", or "U.S. Individual".
        
             ...
        
             Assuming the  term "U.S." means United States, then the 1040
             would be  for a  "United States  Individual", the 1120 for a
             "United States Corporation".
        
        
             In my  opinion, this  sequence of  logic is misleading.  The
        flyer assumes  that the  term "U.S.  means United  States".  Fair
        enough.   If it  doesn't mean "United States", the flyer does not
        tell us  what else  it might  mean.   So, for  purposes  of  this
        analysis, the term "U.S." means "United States".
        
             However, the  flyer also  states that there is no mention of
        the term  "U.S. Citizen".   This  is technically correct, because
        the IRC  never utilizes a capital "C" when it refers to "citizens
        of the  United States" or "United States citizens" (except when a
        capital "C"  is required  in the  first word  of  a  sentence  or
        heading).   This is  misleading, because  the same  flyer  quotes
        section 7701(a)(30)  which does  mention "citizen  or resident of
        the United  States", i.e.,  "citizen of  the  United  States"  or
        "resident of the United States".
        
             The flyer  also states  that there is no mention of the term
        "Individual" or  "U.S. Individual".   Again,  this is technically
        correct, because  the IRC  utilizes the  lower-case "i"  when  it
        refers to  individuals.   But, for  similar reasons, the flyer is
        misleading because "citizens of the United States" and "residents
        of the United States" are among the "individuals" to whom the IRC
        refers.   This is  so because  "person"  means  and  includes  an
        "individual";   it also  means  and  includes  a  trust,  estate,
        partnership, association,  company or corporation.  Therefore, an
        "individual" is  a person  in the  same way  that a  horse is  an
        animal;   moreover,  using  permissible  substitution,  the  term
        "United States  person" means  and includes  a "U.S. individual".
        The "U.S.  individuals" to  whom the IRC refers are the "citizens
        of the United States" and "residents of the United States".  This
        can be confirmed at 26 CFR 1.1-1 et seq.
        
             For similar  reasons, I  also consider the following excerpt
        of the flyer to be misleading and erroneous:
        
        
             At section  6011, when required by regulations prescribed by
             the Secretary  any person made liable for any tax imposed by
             this title  ... shall  make a  return.   Did  the  Secretary
             prescribe by regulations that a citizen of the United States
             was liable for filing?  No, of course not.
        
                                                         [emphasis added]

        Here's the corresponding section of the CFR:
        
        
             1.6011-1  General requirement of return, statement, or list.
        
             (a)  General rule.  Every person  subject  to  any  tax,  or
             required to  collect any  tax, under Subtitle A of the Code,
             shall make such returns or statements as are required by the
             regulations in  this chapter.  The return or statement shall
             include therein  the information  required by the applicable
             regulations or forms.
        
        
        Another important regulation is the following:
        
        
             1.6012-1  Individuals required to make returns of income.
        
             (a)  Individual citizen or resident --
        
                  (1)  In general.   Except  as provided  in subparagraph
                  (2) of  this paragraph,  an income  tax return  must be
                  filed by  every individual  ... for  each taxable  year
                  beginning after  December 31,  1972,  during  which  he
                  received  $750   or  more  of  gross  income,  if  such
                  individual is:
        
                  (i)  A citizen of the United States, whether residing
                       at home or abroad,
                  (ii) A resident of the United States even though not a
                       citizen thereof ....
        
             
             So, I  think the  T.A.G. flyer  is entirely  wrong  when  it
        states that  "of course"  the Secretary  has "not"  prescribed by
        regulations that  a citizen  of the  United States was liable for
        filing.   I have  just proven  that the  Secretary has prescribed
        regulations which  require a  "citizen of  the United  States" to
        make an  income tax  return, provided  that  his  "gross  income"
        exceeds the specified dollar threshold.  The computation of gross
        income for  nonresident aliens is defined at IRC 872(a);  in most
        situations, that  computation results  in a gross income of zero.
        Frank Brushaber's "gross income" was not zero because he received
        a dividend  from a  "U.S. corporation", namely, the Union Pacific
        Railroad Company.   It  was a  U.S. corporation  because  it  was
        incorporated by Congress.
        
        
             Finally, I  realize that  the California  voter registration
        form does  say "For U.S. Citizens Only" in red letters across the
        top of  the form.   However,  the affidavit  on that registration
        form is the statement that matters:

        
                  READ THIS STATEMENT AND WARNING PRIOR TO SIGNING
        
             I am  a citizen of the United States and will be at least 18
             years of  age at  the time  of the  next election.  I am not
             imprisoned or  on parole  for the conviction of a felony.  I
             certify under penalty of perjury under the laws of the State
             of California that the information on this affidavit is true
             and correct.
        
                                     WARNING
                                        
             Perjury is  punishable by  imprisonment in  state prison for
             two, three or four years.  Section 126 Penal Code
        
                                                   [emphasis in original]
                                                                         
                                                                         
             I contend  that the  "citizen of the United States" to which
        this form  refers is  the same  "citizen of the United States" to
        which the  Internal Revenue  Code refers,  to which  the Code  of
        Federal Regulations refers, and to which the so-called Fourteenth
        Amendment refers.  If you are interested, we have now located two
        Utah  Supreme   Court  cases  which  struck  down  the  so-called
        Fourteenth  Amendment.    The  language  of  Section  1  of  that
        amendment is almost identical to the definition of "citizen" that
        is found in 26 CFR 1.1-1(c).  Given that the so-called Fourteenth
        Amendment was  never properly  approved and adopted, the earliest
        definition of  "citizen of  the United  States" that we have been
        able to find in law is found in the 1866 Civil Rights Act.
        
             Thanks for your consideration.
        
        
        Sincerely yours,
             
        
        
        
        /s/ Mitch Modeleski, Founder
        Account for Better Citizenship
        
        
        copy:  Rleen Joy
               Don Fletcher
        


        

        
                                           c/o P. O. Box 6189
                                           San Rafael, California
                                           Postal Zone 94903-0189/TDC
        
                                           December 22, 1992
        Andrew Melechinsky
        Constitutional Revival
        P. O. Box 3182
        Enfield, Connecticut
        Postal Zone 06083/tdc
        
        Dear Andy:
        
             Thanks very much for your unsigned note, postmarked December
        16, 1992.   In response to my previous question concerning 1:8:17
        in the U.S. Constitution, you wrote the following:
        
        
             Answer.   It is  self evident  that no  state or  any  other
             governing body  is authorized  to make laws for the District
             of Columbia  or other  enclaves which  belong to  the United
             States.   It should  be obvious  that this  provision of the
             Constitution was designed to make Congress the equivalent to
             the Enfield  Town Council  or the  Podunk Board of Selectmen
             for the purpose of governing those areas.
                                                            [my emphasis]
        
        
             I couldn't  agree more  with your  answer.   In fact,  it is
        uncanny how  close our  thinking is  on this  question.    In  my
        research and  writings, I  often refer to Congress as "City Hall"
        for the  federal zone.  In other words, if Congress wants to pass
        a "dog  leash" law  for D.C., it is authorized to do so by 1:8:17
        in the  Constitution.  This dog leash law would apply only inside
        D.C., and nowhere else, right?
        
             Now, let's  use a  similar example,  only  this  time  let's
        incorporate a  tax in our example.  Let's say that Congress wants
        to tax  the sale  of dog  leashes inside  D.C.  This is an excise
        tax, right?   Congress  is empowered to levy excise taxes, right?
        But, here's the rub:  must the tax rate be uniform throughout the
        50 States?
        
             Wait a  minute, you  ask, the  question of  uniformity  only
        applies to federal excises levied inside the 50 States.  This tax
        on the  sale of  dog leashes  only applies inside the District of
        Columbia.   The 50  States are  irrelevant to  the application of
        this  tax  and,  therefore,  the  issue  of  uniformity  is  also
        irrelevant, is  it not?   Such  an excise tax need not be uniform
        throughout the  50 States, because it has no application anywhere
        inside the  50 States.  It is a "municipal" tax.  No State or any
        other governing  body is  authorized to  levy such  a tax  inside
        D.C., just  as Congress  is not  authorized to  levy such  a  tax
        outside D.C. and inside the 50 States.
        
             The key  court  decision  on  this  question  is  Downes  vs
        Bidwell, which  is one  of The Insular Cases, as they are called.
        You might  also read  the several  articles which appeared in the
        Harvard Law  Review on these cases.  I have enclosed a memo which
        I wrote some time ago on exclusive authority as applied to direct
        taxes.
        
             You  also  wrote  that  "it  takes  a  wild  imagination  to
        visualize the  District of  Columbia as a second 'United States'.
        Even if  it was,  it would still be subject to the constraints of
        the Bill  of Rights."   Let's postpone correspondence on the Bill
        of Rights until you and I can clarify our respective positions on
        federal taxing  authority, OK?  In this context, the key question
        is this:   are  federal municipal taxes subject to the uniformity
        and apportionment  rules found in the Constitution?  My answer is
        this:   no, because those restrictions only apply to federal laws
        which are  levied inside  the 50  States.   One  of  the  Supreme
        Court's best  statements on  this dual or heterogeneous attribute
        of federal laws is the following excerpt from the Hooven case:
        
        
             ... [T]he  United States** may acquire territory by conquest
             or by  treaty, and may govern it through the exercise of the
             power of  Congress conferred  by Section  3 of Article IV of
             the Constitution ....
        
             In exercising  this power,  Congress is  not subject  to the
             same constitutional  limitations, as  when it is legislating
             for the  United States***. ... And in general the guaranties
             [sic] of the Constitution, save as they are limitations upon
             the exercise of executive and legislative power when exerted
             for or  over our insular possessions, extend to them only as
             Congress, in  the exercise  of its  legislative  power  over
             territory belonging  to the  United States**, has made those
             guaranties [sic] applicable.
        
                     [Hooven & Allison Co. vs Evatt, 324 U.S. 652 (1945)]
                                                         [emphasis added]
        
        
             Now, let's  imagine, just for the sake of argument, that the
        income tax  provisions in the Internal Revenue Code are municipal
        statutes, which  are "not  subject  to  the  same  constitutional
        limitations" which  apply when  Congress "is  legislating for the
        [50] United  States" of  America.  You will notice that the IRC's
        petroleum taxes  are uniform  throughout the  50 States,  and  in
        those provisions  the term  "State" is  defined to include the 50
        States.   However, when it comes to the graduated income tax, the
        term "State"  is defined to include only the District of Columbia
        (and none  of the  50 States).  Isn't this odd?  Not really, when
        you realize that the graduated income tax is, indeed, a municipal
        statute which  is unaffected  by the uniformity and apportionment
        restrictions in  the  Constitution,  for  the  reasons  discussed
        above.
        
             Last but  not least,  we have in America a government of the
        "United States"  and a  government of each of the several States;
        each has citizens of its own.  Therefore, we have State Citizens,
        and we  have federal  citizens (also  known as  "citizens of  the
        United States").    See  the  Cruikshank  case  for  the  seminal
        authority on  this dual  citizenship.  Now, the exercise of State
        Citizenship is  an unalienable right, endowed by the Creator (see
        the Declaration  of Independence).   But,  and this is important,
        even crucial  to the  issue of taxation, federal citizenship is a
        statutory privilege,  the exercise  of which can be taxed with an
        excise tax without uniformity throughout the 50 States.  The term
        "citizen of  the United States" was first expressed in law by the
        Civil Rights  Act of  1866.  Some people say that it was put into
        the Constitution by the so-called 14th Amendment, but we have now
        located two  (2) Utah  Supreme Court  cases which  held that  the
        Amendment was  not properly  ratified.   Therefore, the status of
        "United States  citizen" is at best the creation of Congressional
        legislation -- endowed by Congress and NOT by the Creator.
        
             So, think  of federal  citizens as  citizens of  the federal
        zone.   The taxation  of their incomes is a municipal excise tax,
        just like  the tax  on dog leashes discussed above.  The "income"
        is not  the subject  of the  tax;   the subject of the tax is the
        exercise of  the statutory privilege known as federal citizenship
        (also known  as "U.S.  citizenship").  The "income" is simply the
        measure of the tax.
        
             I hope  I have  made some  sense out  of the jungle of legal
        jargon and double-talk which gets in the way of clear thinking on
        this subject.   Admittedly, the whole situation is made immensely
        complicated by  the deliberate vagueness and confusion which were
        incorporated into  Title 26 and its regulations in the CFR.  But,
        I am  confident we  have now proven that the graduated income tax
        provisions of Title 26 are municipal statutes which apply only to
        the federal  zone (e.g. federal employees) and to the citizens of
        that zone, no matter where they might "reside".  In fact, to be a
        "resident" of  California, strictly speaking, means that one is a
        federal citizen  who resides  outside the federal zone and inside
        California.   Technically speaking,  a  State  Citizen  does  not
        "reside" in the State of his domicile.
        
             I would  appreciate getting your written comments on all the
        above.   In the  meantime, thanks  for your  continuing  work  to
        benefit the Freedom Movement in America today.
        
        
        Sincerely yours,
        
        
        
        
        /s/ Mitch Modeleski, Founder
        Account for Better Citizenship
        



        
                                           c/o P. O. Box 6189
                                           San Rafael, California
                                           Postal Zone 94903-0189/TDC
                                           November 4, 1992
        Karl Loren, Author
        1831 North Bel Aire Drive
        Burbank, California Republic
        Postal Zone 91504/tdc
        
        Dear Karl:
        
             Thank you  for the  complimentary copy  of Verity, Volume 2,
        Number 10, dated November 1, 1992.  Although I do not care to get
        embroiled in  the trust  controversy described  in this  issue of
        Verity, your  newsletter does  contain the  following  paragraphs
        which, in  my humble opinion, contain serious errors.  Numbers in
        [brackets] are my paragraph numbers, for ease of reference:
        
        
        [1]       We in  the United  States tax  U.S. Citizens  on  their
             income whether  they live  in  the  U.S.  or  in  a  foreign
             country.     We  tax  those  U.S.  Citizens,  regardless  of
             residence, on  their income  whether they  received it  from
             within the United States or from outside the United States.
        
        [2]       We even  go so  far as  to tax aliens who reside within
             the United  States -- on their income from either within the
             U.S. or outside the U.S.
        
        [3]       A U.S.  Supreme Court  case [Cook  v. Tait, 265 U.S. 47
             (1924)] requires the U.S. Citizen abroad to pay taxes in the
             U.S.
        
        [4]       The Supreme  court ruled  in this  case that the United
             States has  the power to tax its citizens on their worldwide
             income solely by reason of their citizenship.
        
        [5]       "No  other   major  country  in  the  world  taxes  its
             nonresident citizens on their foreign-source incomes at all"
             according to  Marshall J.  Langer, Professor  of Law,  Miami
             University, author  of Practical International Tax Planning.
             There is even a tax law that makes it illegal to change your
             U.S. citizenship for the purpose of avoiding taxes!  [citing
             IRC Section 877(a)]
        
        [6]       We even  go so  far as  to tax  nonresident aliens  who
             reside outside  the U.S., but who receive income FROM within
             the United States. [citing IRC Sections 871(a) and 871(b)]
        
        [7]       But, the  IRS certainly  does not try to collect income
             taxes from  a nonresident alien who receives his ONLY income
             from sources without the United States.
        
        [8]       It would  be ludicrous  to even  pause to  consider the
             possibility of  the United  States claiming tax jurisdiction
             over a  nonresident  alien  earning  income  from  a  non-US
             Source!
        
        
             I am  somewhat chagrinned  to be  writing this letter in the
        first place,  because you  purchased The Federal Zone some months
        ago, and  your written  communications to me seemed to imply that
        you understood,  and agreed  with, the  book.   The above  quoted
        paragraphs from  Verity, dated  November 1,  1992, now  leave  me
        wondering just how much of The Federal Zone you actually read and
        understood.   Let me proceed with an analysis of your statements,
        paragraph-by-paragraph:
        
        
        [1]       The Internal  Revenue Code (26 USC) and the regulations
             which promulgate  that Code  (26 CFR)  do not impose federal
             income taxes  on "U.S. Citizens".  The regulations at 26 CFR
             1.1-1(b) and  (c) state that income tax liability is imposed
             on the  worldwide income  of "citizens of the United States"
             and "residents  of the United States".  In English, there is
             a world  of difference  between a  proper noun  and a common
             noun.   Proper nouns are capitalized;  common nouns are not.
             If you  think  this  distinction  is  irrelevant  or  merely
             academic, then  it is  now incumbent  upon you  to carry the
             burden of  finding and demonstrating one single reference to
             "U.S. Citizens"  in the IRC and its regulations.  References
             to "Citizen"  or "Citizens" in the first word of a sentence,
             or in  paragraph headings,  do  not  count,  because  formal
             English requires that terms in such grammatical positions be
             capitalized.
        
                  Moreover, the  Hooven case  quoted and discussed in The
             Federal Zone  proves that  the term  "United States"  has at
             least three  different  meanings  in  law.    This  fact  is
             supported by  the same  meanings which  are found in Black's
             Law Dictionary,  Sixth Edition.   The  late John  Knox  once
             confided to  me that  the Solicitor  General in  De Lima  vs
             Bidwell actually argued that the term "United States" has at
             least five (5) different meanings in the Constitution.  I am
             also told that James Madison anticipated the ambiguity found
             in the  term "United  States", and documented this ambiguity
             in his  notes on the Constitutional Convention.  These notes
             were reportedly  published in  1840, but to date I have been
             unsuccessful in  locating a  copy  of  these  notes.    Your
             paragraph [1]  is ambiguous  for failing to define precisely
             which of  these several meanings you are utilizing.  This is
             crucial  because  you  make  the  all-important  distinction
             between income  derived  from  sources  within  the  "United
             States" and  income derived from sources without the "United
             States".    A  precise  definition  of  "United  States"  is
             therefore pivotal  to any and all discussions of federal tax
             law.
        
                  Moreover, the  50 States  are considered to be "foreign
             countries" with respect to the "United States", for purposes
             of federal  taxation, because the regulations clearly define
             the "United  States" to  be the  territory  over  which  the
             federal government  has exclusive  rights.  This is the very
             same term  that is  found in  1:8:17 in the Constitution and
             for this  reason "exclusive" is also a pivotal term.  The 50
             States of  the Union  retain all  rights not reserved by the
             people  and   not  explicitly  enumerated  for  the  federal
             government  by  the  Constitution  (see  the  9th  and  10th
             Amendments for proof).
        
        
        [2]       Again,  this  paragraph  fails  to  provide  a  precise
             definition of "United States".  Moreover, it makes reference
             to "aliens"  who "reside  within the United States".  If you
             study IRC  7701(b)(1)(B) very  carefully, you  will discover
             that an  "alien" is  an individual  who is not a "citizen of
             the United  States" and a "nonresident" is an individual who
             is not  a "resident of the United States (within the meaning
             of  subparagraph  (A)".    IRC  7701(b)(1)(A)  is  important
             because  it   defines  the  three  tests  which  distinguish
             "resident aliens"  from "nonresident  aliens".   These three
             tests are  the only  ways in  which  an  "alien"  can  be  a
             "resident alien".    Therefore,  these  three  tests  define
             "residence" for  purposes of  federal income  taxation.  See
             also IRS Publication 519:  "For tax purposes, an alien is an
             individual who  is not  a U.S. citizen."  Therefore, a State
             Citizen who  is not  also a  federal citizen is an alien for
             federal tax  purposes.   Your paragraph  [2]  is  vague  and
             therefore void.
        
        [3]       Again, you  make reference  to a  "U.S. Citizen".   See
             discussion of paragraph [1] above.
        
        [4]       Now you  make reference  to the  "United States",  "its
             citizens" and "their citizenship".  Oddly, this paragraph is
             grammatically and legally correct, because the Congress does
             have exclusive legislative jurisdiction over its own federal
             citizens, no matter where on planet Earth they may "reside".
             The enclosed  materials go  into great  depth to explain the
             distinction between  federal citizens and State Citizens, so
             I won't  belabor this  distinction here.  It is important to
             realize that  the distinction  between these  two classes of
             citizenship  is   as  important   and  fundamental   as  the
             distinction between  the State and federal governments.  See
             the Cruikshank  case, K.  Tashiro vs  Jordan, and  Ex  parte
             Knowles for  proof.   The  Slaughter  House  Cases  are  the
             seminal decisions  in this  area.   If you  fail to  educate
             yourself  about  this  important  legal  history,  you  will
             continue to propagate the kind of confusion which is evident
             in Verity for November 1, 1992.
        
        [5]       Here again  you are  back on track, but it is not clear
             whether you  are back  on track knowingly and intentionally,
             or not.   Congress  has authority  to tax  its  own  federal
             citizens, wherever  they reside  and wherever  the source of
             their  income.      Therefore,   "resident   citizens"   and
             "nonresident citizens"  are treated  the same in federal tax
             law because  the worldwide  income of  both groups is taxed.
             Your paragraph  [5] does  make a grievous error, however, by
             stating that  the tax  law makes  it illegal  to change your
             "U.S. citizenship"  for the purpose of avoiding taxes.  Your
             paragraph [5]  then cites  IRC 877(a).   This  is  not  what
             Section 877(a) says, nor is expatriation made illegal by any
             subparagraphs of  Section 877.   Read  them!  IRC 877 merely
             discusses the rules which shall govern federal tax liability
             when expatriation occurs.  It does not outlaw expatriation!
        
        [6]       This paragraph  is also correct on its face, but it too
             suffers for  lacking a precise definition of "United States"
             and "U.S."   Sections  871(a) and 871(b) are governed by the
             statutory definition of "United States" that is found at IRC
             7701(a)(9).   This definition,  in turn,  is governed by the
             statutory  definition  of  "State"  that  is  found  at  IRC
             7701(a)(10).   IT IS  VERY IMPORTANT TO TAKE CAREFUL NOTE OF
             THE EXACT WORDING OF 7701(a)(10):
        
                  The term  "State" shall  be construed  to  include  the
                  District  of   Columbia,  where  such  construction  is
                  necessary to carry out the provisions of this title.
        
                                                         [emphasis added]
                                                                         
                  Now,  it   is  true   that  the  terms  "includes"  and
             "including" are  qualified by  IRC 7701(c),  but notice that
             "include" is  not qualified  by IRC  7701(c).  This may seem
             like nit-picking,  but  the  published  rules  of  statutory
             construction do  apply here.    Specifically,  the  rule  of
             inclusio unius  est exclusio  alterius (the inclusion of one
             is the  exclusion of  others)  states  that  an  irrefutable
             inference must  be drawn  that what  is omitted  or excluded
             from a  statutory definition  was intended  to be omitted or
             excluded.  The term "include" is excluded from 7701(c).  The
             term "California"  is excluded from 7701(a)(10).  Therefore,
             all by itself, this rule of statutory construction allows us
             to infer that "include" is not expansive and "California" is
             excluded from  the statutory  definition of "State" found at
             7701(a)(10).
        
                  There are  other rules  of statutory construction which
             produce the  same result, e.g., ejusdem generis (the federal
             zone and  the 50 States are not in the same general class of
             entities because  the 50  States are  members of  the Union,
             while the  areas within  the federal zone are not).  Now the
             burden is  upon you  to prove  otherwise.  Don't forget that
             any doubt  must be  resolved in favor of those upon whom the
             tax is  sought to  be laid;   the Supreme Court has said so,
             more than once!
        
        [7]       The IRS most certainly does try to collect income taxes
             from nonresident  aliens who  receive their ONLY income from
             sources without the "United States".  For purposes of income
             taxation, the  "United States"  as defined  in the IRC is no
             larger than  the territory  over  which  Congress  exercises
             exclusive legislative authority, i.e., the federal zone.  If
             you study Treasury Decision 2313 carefully, you will come to
             discover that Frank Brushaber was classified by the Treasury
             Department as  a nonresident  alien.   His  court  documents
             prove that  he claimed  to be  a State Citizen who lived and
             worked in  New York City.  Therefore, State Citizens who are
             not also federal citizens are "nonresident aliens" as far as
             federal income  taxes are  concerned.   How many millions of
             Americans  have   been  victimized  by  the  deliberate  and
             criminal confusion  which has  been fostered  by  vague  and
             ambiguous terms  in the  IRC?   I say  at least 100 million,
             counting all  those who  have paid  income taxes  and passed
             away since 1913.
        
        [8]       It certainly  is ludicrous  for the  "United States" to
             claim tax  jurisdiction over  nonresident  aliens  who  earn
             income from  "non-US" sources,  but IT  makes this claim all
             the time.  By IT I mean the authority granted to Congress by
             1:8:17 and  4:3:2 in  the U.S. Constitution, which authority
             MUST be  lawfully delegated  to the Internal Revenue Service
             (a private  mercantile organization  which collects interest
             payments for the Federal Reserve banks).
        
                  The evidence  is overwhelming that Congress simply does
             not have exclusive legislative authority over the 50 States.
             The study  entitled "Jurisdiction  Over Federal Areas Within
             the States" makes this case over and over and over.  At last
             count, this  study cites  more than  700 federal  and  state
             court cases  which all  found the same thing:  Congress does
             not enjoy  exclusive  legislative  jurisdiction  inside  the
             boundaries of  the  50  States  until  and  unless  a  State
             Legislature cedes  its sovereign  jurisdiction to  Congress,
             and does  so for  a  specific  parcel  of  land  (called  an
             "enclave").
        
                  At this  point in  the game,  Karl, you  can no  longer
             claim ignorance  of this massive body of case law.  Congress
             cannot impose a direct tax on State Citizens unless that tax
             is duly  apportioned.   The earnings  of State  Citizens are
             exempt  from   taxation  by   the  fundamental   law.    The
             apportionment rule  is found  in the  fundamental  law,  but
             there  are  no  apportionment  provisions  anywhere  in  the
             Internal Revenue  Code.  The burden is now upon you to prove
             otherwise!
        
             A man  with your  intelligence should  not hesitate to admit
        that the  ambiguities in Title 26 had to be intentional.  We know
        that the  Treasury Department  can be  clear when  it needs to be
        clear.   The most  important ambiguity  is found  in the  several
        meanings of  "State" and  "United States"  in the statute and its
        regulations.   There is an obvious reason why the definitions are
        not crystal  clear and completely unambiguous, and that reason is
        MONEY.   A crystal clear and completely unambiguous definition of
        federal income  tax jurisdiction  would limit  the definition  of
        "United States"  to the  federal zone  and no  more.   There is a
        massive amount  of case  law which  proves that Congress does not
        exercise exclusive  legislative  jurisdiction  upon  any  of  the
        Citizens or the territory of the 50 States.
        
             In support of all my observations above, I have enclosed for
        your information  the drafts  of several  chapters from the third
        edition of The Federal Zone, which has not yet been published.  I
        strongly encourage  you to  devour this  material, and  also  the
        court cases and other publications cited therein.  If you persist
        in claiming  that there  is nothing  to  be  made  of  difference
        between "Citizens"  and "citizens",  particularly in  the face of
        all the  evidence which I am now sharing with you, then I will be
        forced to  conclude that  you and I going in opposite directions.
        At the  very least,  I will  be  forced  to  conclude  that  your
        understanding of  federal tax law does not warrant the high costs
        you are charging for your trust advisory services.
        
        
        Sincerely yours,
        
        
        
        
        /s/ Mitch Modeleski, Founder
        Account for Better Citizenship
        
        enclosures
        
        

        

                                           c/o USPS P. O. Box 6189
                                           San Rafael, California
                                           Postal Code 94903-0189/TDC
        
                                           October 1, 1992
        Hi John,
        
             I've continued  to think about De Ganay vs Lederer, 250 U.S.
        376.   Here's a  decision table to help us organize our thoughts.
        It is  not necessarily  rigorous or  exhaustive, but  provides  a
        useful framework.   For what it's worth, this table distinguishes
        stockholder dividends from corporate profits, as follows:
        
        
        Case 1:
        Both stockholder and corporation are overseas.
        
        Plaintiff Defendant 16th Result
        
        overseas  overseas  yes  Congress cannot tax at all because
        NRA       corp.          both are beyond its jurisdiction.
        
        overseas  overseas  no   Congress cannot tax at all because
        NRA       corp.          both are beyond its jurisdiction.
        
        The decisive  factor here  is territorial jurisdiction.  The 16th
        Amendment is irrelevant.
        
        
        Case 2:
        Corporation is  chartered by a Union State (a/k/a "State corp.").
        The tax on stockholder dividends is a "direct" tax, per Pollock.
        
        Plaintiff Defendant 16th Result
        
        overseas  State     yes  Congress can tax without apportionment
        NRA       corp.          because stockholder is not protected by
                                 the Constitution.
        
        overseas  State     no   Congress can tax without apportionment,
        NRA       corp.          because stockholder is not protected by
                                 the Constitution.
        
        State     State     yes  Congress can tax without apportionment
        Citizen   corp.          if both are inside a Union State.
        
        State     State     no   Congress cannot tax without apportion,
        Citizen   corp.          Congress can    tax with    apportion,
                                 if both are inside a Union State.
        
        The decisive  factor here  is  the  protection  afforded  by  the
        applicable Constitution(s),  if any.   Note  that a ratified 16th
        Amendment makes  a difference  for State  Citizens, but  not  for
        overseas NRA's.

        Case 3:
        Corporation is  chartered by a Union State (a/k/a "State corp.").
        The tax on corporate profits is always an "indirect" tax:
        
        Plaintiff Defendant 16th Result
        
        either    State     yes  Congress can tax if tax is uniform and
        NRA       corp.          corporation is inside a Union State.
        
        either    State     no   Congress can tax if tax is uniform and
        NRA       corp.          corporation is inside a Union State.
        
        The decisive  factor here  is that  profit  generation  by  State
        corporations is  a revenue-taxable  activity because corporations
        are privileged  creations of government (they enjoy the privilege
        of limited liability).  The tax rates must be uniform, however.
        
        Case 4:
        Corporation is chartered inside federal zone (a/k/a "domestic").
        The tax on corporate profits is always an indirect tax.
        
        Plaintiff Defendant 16th Result
        
        either    domestic  yes  inside federal zone, Congress can tax
        NRA       corp.          without uniformity or apportionment
        
        either    domestic  no   inside federal zone, Congress can tax
        NRA       corp.          without uniformity or apportionment
        
        The decisive  factor here is that profit generation by "domestic"
        corporations  is   a  revenue-taxable   activity  because   these
        corporations are  privileged creations  of Congress.   Tax  rates
        need not  be uniform or apportioned;  only majority rule needs to
        be satisfied.
        
        Summary
        
             Thus, if  my analysis  of corporate  profits is correct, the
        16th Amendment  is not  relevant,  even  if  the  corporation  is
        chartered by  a Union State.  Congress is free to define a tax on
        corporate profit as an excise tax, and Congress need only satisfy
        the uniformity  rule if  the corporation  is chartered by a Union
        State.     Congress  need  only  satisfy  majority  rule  if  the
        corporation is chartered inside the federal zone (see Chapter 13,
        3rd edition).
        
             The  situation   is  a  bit  different  if  the  subject  is
        dividends.   The  status  of  dividend  recipients  then  becomes
        relevant, as  does the  ratification of  the 16th  Amendment.   I
        distinguish dividends  from profits  because they  can  be  taxed
        separately.   There is  no compelling logical reason why dividend
        payors must  be held  liable for  the tax on dividends;  dividend
        recipients could  be designated  the liable  party  (if  not  the
        withholding agent).
        
             So, the  De Ganay  case does  not represent  a threat to the
        thesis of  The Federal  Zone after  all.   This is so because the
        dividend recipient  was unprotected  by the  Constitution and the
        corporation  was   engaged  in   a  privileged,   revenue-taxable
        activity, even  if  it  was  chartered  by  the  Commonwealth  of
        Pennsylvania.
        
             If this  analysis  does  anything,  it  reveals  a  need  to
        distinguish overseas  NRA's (like  Emily  De  Ganay)  from  State
        Citizens (like Frank R. Brushaber).  The current Internal Revenue
        Code does not make this distinction, however.
        
        
        Sincerely yours,
        
        
        
        
        /s/ Mitch Modeleski, Founder
        Account for Better Citizenship
        
        

        
                           Conklin Rebuttal (briefly)
                                        
                                       by
                                        
                            Mitch Modeleski, Founder
                         Account for Better Citizenship
        
                                  July 4, 1992
        
        
        Liability of Individuals
        
        Conklin is  saying that  nobody is  made liable for income taxes.
        His ad  in The  Connector of  May 1992  stated:  "My name is Bill
        Conklin and  I have searched the Internal Revenue code for twelve
        years:   it is  my opinion after extensive research that there is
        no statute  that makes  anyone liable  for the  income  tax  ..."
        [emphasis added].  This statement is wrong;  "withholding agents"
        are specifically  made liable  by Sections  1441 and  1461 of the
        Internal Revenue Code (IRC).
        
        Effect of Regulations
        
        Conklin has  written privately  that Congress  cannot  promulgate
        regulations which exceed the statute and that a regulation cannot
        exceed the limitations created by the statute.  The preponderance
        of case  law proves  that the  regulations in  26 CFR do have the
        force and  effect of  law.   See 2 Am Jur 2d, Section 289 et seq.
        See also  the Federal  Register Act  and Administrative Procedure
        Act.  The regulations in 26 CFR are not so easily swept away.
        
        In re: Becraft
        
        This is  not a good decision because Becraft's research concludes
        that only  "aliens here  and  citizens  abroad"  are  liable  for
        federal income  taxes.  This conclusion is easily disproven by 26
        CFR 1.1-1(b),  one of the key regulations which define the income
        tax liability of individuals:
        
             In general,  all citizens  of the  United States**, wherever
             resident, and  all resident  alien individuals are liable to
             the income  taxes imposed  by the Code whether the income is
             received from sources within or without the United States**.
        
                                        [26 CFR 1.1-1(b), emphasis added]
        
        Moreover, that  court reduced Becraft's argument to one elemental
        proposition, and rejected it for "absurdity" and "frivolity":
        
             The  Sixteenth   Amendment  does   not  authorize  a  direct
             non-apportioned  income   tax  on   resident  United  States
             citizens [sic] and thus such citizens are not subject to the
             federal income  tax laws.   We  hardly need  comment on  the
             patent absurdity and frivolity of such a proposition.
        
        Well, the  Brushaber decision  found otherwise.    Moreover,  the
        Becraft court  uses the  term "resident  United States  citizen",
        which  manifests   a  lack   of  understanding  of  the  relevant
        regulations and  their legislative  history.   The  citizen/alien
        dimension is  a birth  status (or  naturalization status).    The
        resident/nonresident dimension  is a  location status.   The term
        "resident United  States citizen" only makes sense if one intends
        to distinguish  it  from  "nonresident  United  States  citizen",
        "resident alien"  and "nonresident  alien".   The  Becraft  court
        would benefit  enormously by mastering The Matrix as explained in
        The Federal Zone.  Their failure to define terms is a serious, if
        not fatal flaw.
        
        U.S. vs Collins
        
        *    By citing  Collins as an authority for defeating The Federal
             Zone thesis,  Conklin confuses  judicial  jurisdiction  with
             legislative jurisdiction.   The two are obviously different:
             district  court   jurisdiction  is   created   by   statute,
             legislative jurisdiction is created by the Constitution.
        
        *    Collins ruled:  "The argument  that the  sixteenth amendment
             does not  authorize a  direct, non-apportioned tax on United
             States citizens similarly is devoid of any arguable basis in
             law" [emphasis added].  This statement is demonstrably false
             because the Brushaber decision supports this argument.
        
        *    Collins also  ruled:   "For seventy-five  years, the Supreme
             Court has recognized that the sixteenth amendment authorizes
             a direct  nonapportioned tax  upon  United  States  citizens
             throughout the  nation, not  just in  federal enclaves,  see
             Brushaber ...."   Brushaber  is NOT  an authority  for  this
             statement;   Brushaber ruled  that income taxes are indirect
             taxes and  the only  effect of  the 16th  Amendment  was  to
             overturn the Pollock principle.  Read it!
        
        The existence  of one  or more  apparently unfavorable cases does
        not invalidate The Federal Zone (see Unfavorable Case Law below).
        
        Sixteenth Amendment
        
        Most federal  courts refuse to recognize the mountain of material
        evidence which  impugns the  ratification of  the so-called  16th
        Amendment.  However, the judge in U.S. vs Benson admitted, on the
        record, that  there is  no law  if Bill  Benson is  correct.   By
        citing Collins,  Conklin is  siding with irresponsible judges who
        label the  evidence a  "political" question.   Well,  it wasn't a
        "political" question in the years immediately after the amendment
        was "declared"  ratified.  Both the Collins and Becraft decisions
        are badly  defective because  they attempt to sustain the obvious
        fiction that  there is  no material  evidence  against  the  16th
        Amendment.  Mr. Conklin needs to choose between fact and fiction.
        (Racing firemen don't stop for curb dogs.)
        
        
        Treasury Decision 2313
        
        This Treasury  Decision is  crucial  evidence  that  The  Federal
        Zone's status  and  jurisdiction  arguments  are  valid.    Frank
        Brushaber declared  himself to  be a  citizen of the State of New
        York, and  a resident  of the Borough of Brooklyn, in the City of
        New York.   Both  the federal  courts and the Treasury Department
        found that  Frank Brushaber was a NONRESIDENT ALIEN, according to
        their own  rules!  The Secretary of the Treasury had no basis for
        extending T.D.  2313  to  those  who  were  not  parties  to  the
        Brushaber case.   Frank  Brushaber did  err in  assuming that his
        defendant was  a foreign corporation;  the Union Pacific Railroad
        Company was  a domestic  corporation, because  it was  originally
        created by  an Act of Congress.  Conklin has neglected to mention
        T.D. 2313 anywhere in his published and private communications.
        
        The Three United States
        
        The Hooven  case is standing authority for the fact that the term
        "United States"  has three  separate meanings, all different from
        each other.   Federal  courts had an excuse before this decision;
        but after  Hooven, courts  have no  excuse for failing to specify
        which of  these three  meanings they  intend, with each and every
        use of  the term.  This lack of specificity leads to uncertainty,
        which leads  in turn  to court  decisions which are also void for
        vagueness.   The 6th  Amendment guarantees  our right  to  ignore
        vague and  ambiguous laws, and this must be extended to vague and
        ambiguous case  law.  Moreover, Hooven is also standing authority
        for the  principle of  territorial  heterogeneity,  an  important
        theme  in   The  Federal   Zone  which   Conklin  ignores  almost
        completely.   Similarly, Conklin  has failed even to mention "The
        Insular Cases" or to deal with the obvious relevance of Downes vs
        Bidwell,  namely,  excise  uniformity  doesn't  rule  inside  the
        federal zone;  the majority rules inside the federal zone.
        
        Knowledge of the Book
        
        Conklin has  not purchased The Federal Zone, and has yet to admit
        that he  has even  read the book.  The failed ratification of the
        Sixteenth Amendment figures prominently in the book's main logic.
        Territorial heterogeneity is a theme which Conklin ignores almost
        completely.   The "void for vagueness" doctrine affords all of us
        an opportunity  to agree,  on the  vagueness at  least.   If  the
        statute is  clear, then why did Conklin fail to find the sections
        that make  withholding agents  liable?   He had  12 years, and he
        still missed them.  The Spreckels case ruled that "doubt is to be
        resolved in  favor of  those upon  whom the  tax is  sought to be
        laid."   Wigglesworth ruled  that, in  case  of  doubt,  statutes
        levying  taxes   "are  construed   most  strongly   against   the
        Government, and  in favor of the citizen".  The continuing debate
        on all  sides is important empirical proof that the IRC should be
        nullified for  vagueness.   If the Supreme Court cannot be clear,
        then nobody can;  and their titles are Justice.

        
        Unfavorable Case Law
        
        The existence  of one  or more  apparently unfavorable cases does
        not invalidate  The Federal  Zone, particularly  when those cases
        are  predicated   on  rebuttable   assumptions  (like   the  16th
        Amendment, or  "clarity" in the statute, or arbitrary definitions
        of "income").   The book proves that chaos exists in the relevant
        federal cases:  the Supreme Court has clearly contradicted itself
        when defining  the effects  of a  ratified 16th  Amendment.  "The
        devil  can  quote  scripture  for  his  purpose,"  wrote  William
        Shakespeare.   With courts  in conflict, one can cite authorities
        for either  side of  any such  unresolved debates.  The Prince of
        Darkness is also the Prince of Lies.
        
        Private Law
        
        There are  many mysteries  which are  amazingly clarified  by The
        Federal Zone, including the "private law" nature of the IRC.  The
        IRC is a municipal statute for the federal zone.  Congress is the
        sovereign municipal  authority for the federal zone.  If Congress
        had intended  the IRC  to apply  to all 50 States, Title 26 would
        have need to be enacted into positive, "public" law.  It was not.
        (For details, see Super Gun by Lori Jacques, pages 74-81.)
        
        Uniform Commercial Code
        
        The UCC  is precisely  on point,  because federal tax returns are
        "foreign  bills   of  exchange"   which  are  subject  to  rules,
        regulations and case law which have built up around the UCC.  The
        50 States are "foreign" to each other, just as each is foreign to
        the federal  zone (see  In re  Merriam).   The UCC  has  explicit
        provisions for  reserving the  unalienable rights  of  those  who
        enter such  contracts, including  but not limited to the right to
        due  process   and  the   immunity  against   self-incrimination.
        Moreover, the UCC has a guarantee that statutes must be construed
        in harmony  with the  Common Law.   The  U.S. Constitution is the
        last vestige of the Common Law at the federal level.
        
        The Smoking Gun
        
        The Federal  Zone documents  the "smoking  gun" --  awesome proof
        that  the  vagueness,  deception,  confusion  and  jurisdictional
        ambiguities in Title 26 were intentional.


        
        MEMO
        
        TO:       John Voss, Director, N.C.B.A.
                  other interested parties
        
        FROM:     Mitch Modeleski, Founder
                  Account for Better Citizenship
        
        DATE:     June 9, 1992
        
        SUBJECT:  Do the regulations in 26 C.F.R.
                  have the force and effect of law?
        
        
        The debate  fostered by  the claims  on N.C.B.A.'s $50,000 Reward
        appears to have reached the following point of departure:
        
        
             Mr. Conklin has argued that Title 26 makes nobody liable for
             federal income taxes.
        
             This argument was defeated by reference to clear sections of
             Title 26  which make "withholding agents" liable for federal
             income taxes.
        
             I do not as yet know if Mr. Conklin is a withholding agent.
        
             In a private communication, Mr. Conklin has also argued that
             the regulations  in 26 C.F.R. create no liability because "a
             regulation cannot  exceed the  limitations  created  by  the
             statute."
        
        
        The purpose  of the remainder of this memo is to cite some of the
        case law  which is  relevant to the questions of validity, and of
        the legal  force and  effect, of  regulations promulgated  by the
        Secretary of  the Treasury.  The attached abstracts from American
        Jurisprudence reveal  a substantial body of case law which is not
        always entirely consistent on this question.  For example:
        
        
             A regulation cannot supply omissions of the statute.
        
                                               [2 Am Jur 2d, Section 289]
                                      -but-
        
             A regulation which fulfills the purpose of the law cannot be
             said to be an addition to the law.
        
                                                     [ibid., Section 300]
        
        
        The following  are notable  excerpts from  the  attached  Am  Jur
        sections that deal with the effect and validity of rules:
        
             Rules,  regulations,   and   general   orders   enacted   by
             administrative agencies  pursuant to the powers delegated to
             them have the force and effect of law.  [page 119]
        
             There have  been applied  to administrative  regulations the
             principles that everyone is presumed to know the law or that
             ignorance of  the law is no excuse, and the courts will take
             judicial notice of them.  [page 120]
        
             ... [T]here  is no  violation of the Federal Constitution in
             an act of Congress which provides for a defense to an action
             under the  statute based  on good  faith reliance  upon  any
             administrative regulation ....  [page 120]
        
             Administrative regulations are held to be "laws" for various
             purposes, including  jurisdiction  of  courts  and  criminal
             liability.   If  Congress  imposes  criminal  sanctions  for
             disobedience of regulations, it can hardly be contended that
             such regulations  are not  a "law"  for the  purposes of the
             Criminal Code.  [page 121]
        
             Compliance  with   valid   administrative   regulations   is
             compliance with law, as has been held where it was sought to
             induce actions  contrary to  the regulations  or  to  impose
             liability  for  actions  which  accorded  with  regulations.
             [page 122]
        
             Valid administrative  rules  or  regulations  are  generally
             regarded as legislative enactments, and have the same effect
             as if  enacted by the legislature.  They have the force of a
             statute and  the same  effect as  if part  of  the  original
             statute.   They  become  integral  parts  of  the  statutes,
             particularly where  they are  legislative in  nature -- that
             is, are called for by the statute itself.  [page 122]
        
             While in  the strict  sense of  the term  an  administrative
             regulation is  not actually  a "statute"  but is  at most an
             offspring of  a statute,  a regulation may be deemed to come
             within the term "statute."  [page 123]
        
             ...[R]ules and  regulations will  be upheld  where they  are
             within the statutory authority of the agency and reasonable,
             ... they  must be  sustained unless unreasonable and plainly
             inconsistent with the statute.  [page 123]
        
             Only  when   discretion  has   been  arbitrarily  exercised,
             resulting  in   injustice  or   unfairness,  do  the  courts
             intervene to  strike down  a rule  promulgated by the proper
             agency designed to give appropriate effect to the provisions
             of the act involved.  [page 124]
        
             Administrative  regulations   which  go   beyond  what   the
             legislature can  authorize are  void and may be disregarded.
             [page 124]
        
             Regulations which are legislative in character should not be
             overruled by  the courts unless clearly contrary to the will
             of the legislature.  [page 124]
        
             Thus there are applicable the rules in regard to presumption
             of validity  and partial or entire invalidity;  and, just as
             in  individual   cases  hardship  and  loss  may  flow  from
             legislative  acts   which   are   nevertheless   valid,   so
             administrative regulations may also operate.  [page 125]
        
             Administrative rules  and regulations,  to be valid, must be
             within  the  authority  conferred  upon  the  administrative
             agency.   A rule  or regulation  which is  broader than  the
             statute empowering  the making  of rules, or which oversteps
             the boundaries  of interpretation  of a statute by extending
             or restricting  the statute  contrary to its meaning, cannot
             be sustained.  [page 127]
        
             They are valid and binding only when they are in furtherance
             of the  intention of  the legislature  as evidenced  by  its
             acts, and  a regulation,  valid  when  promulgated,  becomes
             invalid upon the enactment of a statute in conflict with the
             regulation.   However, an administrative regulation will not
             be  considered  as  having  been  impliedly  annulled  by  a
             subsequent  act  of  the  legislature  unless  the  two  are
             irreconcilable, clearly  repugnant, and so inconsistent that
             they cannot have concurrent operation.  [page 127]
        
             Administrative  regulations   which  go   beyond  what   the
             legislature has  authorized, which  violate the  statute, or
             which are  inconsistent or  out of  harmony with the statute
             conferring the power, have been said to be void.  [page 128]
        
             ... [A]dministrative  regulations, to be valid, are required
             to be appropriate, reasonable, or not inconsistent with law.
             A rule  or regulation  which is  within the broad rulemaking
             powers commonly conferred on administrative agencies will be
             sustained by the courts.  [page 128]
        
             ... [A]  regulation which  fulfills the  purpose of  the law
             cannot be  said to be an addition to the law.  Before a rule
             or regulation  may be declared void it must be definitely in
             excess of  the scope  of authority,  or plainly  or palpably
             inconsistent with law.  [page 129]
        
             ... [A]n  administrative agency  may not  create a  criminal
             offense or  any liability  not sanctioned  by the  lawmaking
             authority, especially  a liability  for a  tax or inspection
             fee.  [page 129]
        
             ... [I]ssuance  of regulations  is  in  effect  exercise  of
             delegated legislative power.  [page 770]
        
             Administrative Procedure  Act ...  and Federal  Register Act
             ... set  up procedure  which must  be followed  in order for
             agency rulings to be given force of law.  [page 770]
        
             Contents of  Federal Register are judicially noticed and may
             be cited by volume and page number.  [page 772]
        
             ... [F]ederal courts are required to take judicial notice of
             contents of Federal Register.  [page 772]
        
             Code  of   Federal  Regulations   being  nothing  more  than
             supplemental edition  of Federal Register, court is entitled
             to take  judicial notice  of cited  regulation in  brief  of
             prosecution[,] and  conviction of  defendant thereon  is not
             precluded  by   government's  failure   to  introduce   such
             applicable section in evidence.  [page 772]
        
             Court was  required to  take judicial  notice of the Federal
             Register and the Code of Federal Regulations.  [page 772]
        
        
        In closing, the following excerpt from an unpublished treatise by
        attorney Lowell  Becraft is  extremely relevant  to the force and
        effect of regulations:
        
        
                           CONSTRUCTION OF REGULATIONS
                                        
                  In  5   U.S.C.,  section   301,  heads   of   Executive
             departments  are   given  authority   to  make  and  publish
             regulations.   It has  been previously  demonstrated how the
             current federal  income tax  laws in  question today  relate
             back to  the 1916  income tax  act.   Section 15 of that act
             defined the  terms "State"  and  "United  States"  in  clear
             jurisdictional  terms.    All  income  tax  acts  passed  by
             Congress have  authorized the  Secretary of  the Treasury to
             promulgate regulations,  which he  has done  since the first
             income tax  act in  1913.  All of the income tax regulations
             published since  January 28,  1921, have  defined the people
             subject to the tax as "citizens of the United States subject
             to its  jurisdiction."  Thus, this phrase has been a part of
             the regulations  for some 67 years, and applied to the 1918,
             1921, 1924,  1926, 1928,  1932, 1934, 1936 and 1938 acts, as
             well as the 1939 and 1954 Codes.
        
                  The Secretary of the Treasury and the United States are
             firmly bound  by these  prior regulations  as  well  as  the
             current Treasury  Regulation  1.1-1(c),  which  defined  the
             subject of  the current  tax as  a "citizen  subject to  its
             jurisdiction."   A long  line of  Supreme Court  cases holds
             that an  executive department  head such as the Secretary of
             the Treasury  is bound  by the regulations he so promulgates
             and publishes ....
        
                  And  the  Supreme  Court  has  found  that  regulations
             consistently promulgated in the same language for repeatedly
             re-enacted laws  are very significant.  In Old Colony R. Co.
             v. Commission  of Internal  Revenue, 284  U.S. 552, 52 S.Ct.
             211 (1932), the Supreme Court held that such regulations are
             given an implied legislative approval:
        
        
                  "The  repeated   re-enactment  of   a  statute  without
                  substantial change may amount to an implied legislative
                  approval of  a construction placed upon it by executive
                  officers," 284 U.S., at 557
        
                                                         [emphasis added]
                                                                         
                                                                         
        This brings us to the following regulation; it mentions liability
        explicitly:
        
        
             In general,  all citizens  of the  United  States,  wherever
             resident, and  all resident  alien individuals are liable to
             the income  taxes imposed  by the Code whether the income is
             received from sources within or without the United States.
        
                                                     [26 C.F.R. 1.1-1(b)]



        MEMO
        
        TO:       John Voss, Director
                  National Commodity and Barter Association
        
        FROM:     Mitch Modeleski, Founder
                  Account for Better Citizenship
        
        DATE:     June 7, 1992
        
        SUBJECT:  Federal Income Tax Liability
        
             
             As distinct  from the  regulations published  in 26  C.F.R.,
        does the  Internal Revenue  Code itself specifically make anybody
        liable for  federal income  taxes?  Answer: a "withholding agent"
        is specifically named as a "person" who is made liable for such a
        tax.   The proof is found in the combination of Sections 1441 and
        1461 of the IRC, as follows:
        
        
             Section 1441.  Withholding of Tax on Nonresident Aliens.
        
             (a)  General  Rule.  --  Except  as  otherwise  provided  in
             subsection (c), all persons, in whatever capacity acting ...
             having the  control, receipt,  custody, disposal, or payment
             of any  of the  items of  income specified in subsection (b)
             (to the  extent that  any of  such items  constitutes  gross
             income from  sources  within  the  United  States),  of  any
             nonresident alien  individual or  of any foreign partnership
             shall ... deduct and withhold from such items a tax equal to
             30 percent  thereof, except  that in the case of any item of
             income specified  in the  second sentence of subsection (b),
             the tax shall be equal to 14 percent of such item.
        
        
             Section 1461.  Liability for Withheld Tax.
        
             Every person  required to  deduct and withhold any tax under
             this chapter  is hereby  made liable  for such  tax  and  is
             hereby indemnified  against the  claims and  demands of  any
             person for  the amount  of any  payments made  in accordance
             with the provisions of this chapter.
        
                                                         [emphasis added]
                                                                         
        
        Therefore, if  Bill Conklin  is a  withholding agent,  then he is
        liable for  the federal  income tax  on the  amount he withholds.
        The question  now becomes:   Is Bill Conklin a withholding agent?
        Yes or  No?   It is  impossible to answer this question from your
        $50,000 Reward  advertisement, and  I cannot tell from any of the
        written communications I have received from him to date.
        
             Now, permit  me to  specify the  conditions under which Bill
        Conklin would  actually be  liable for  such a  tax, by  using  a
        practical and  realistic example.   Let  us say that Bill Conklin
        has a  good friend  named Sam who is an Air Force budget analyst.
        This friend  is responsible  for a  government  research  budget,
        which provides  grants for  research in  various areas  of  human
        resources.  Sam is impressed with Bill Conklin's knowledge of the
        IRC.  With Bill's consent, Sam agrees to hire Bill under contract
        to the  Air Force  to provide  tax consulting  to other Air Force
        budget analysts  like Sam.   When  Bill gets this money, he calls
        his colleague  Mitch to help him work on this project, and agrees
        to pay Mitch a flat rate of $60 per hour from the research grant.
        
             Mitch, by the way, is a nonresident alien, as confirmed by a
        recent formal  affidavit served on the Secretary of the Treasury.
        Having accepted  funds  from  the  Air  Force,  Bill  is  thereby
        receiving money from a source that is "inside the United States".
        Rather than  paying Mitch  the full  $60 per  hour,  the  statute
        requires Bill  to withhold  30 percent  from Mitch's  wages,  per
        Section 1441  of the IRC.  Moreover, Bill Conklin is the "person"
        who is  liable for  this tax, not Mitch.  However, Mitch would be
        required to file a "return" on Form 1040NR, because he had "gross
        income" as  defined in  Section 872(a),  to show that the tax had
        already been  withheld and  therefore paid.   The tax is actually
        paid by the "person made liable", that is, Bill Conklin.
        
             Now, to  elaborate this  example just  a little  more,  Bill
        hires two  more people,  both of  whom declare  themselves to  be
        "United States  citizens" and  both of  whom complete  and sign a
        valid W-4  certificate.   By law, Bill is also required to act as
        their "withholding  agent", albeit  at rates  that are  different
        from the  flat 30  percent levied  against the  gross  income  of
        nonresident aliens.   Graduated  tax rates  are applied  to their
        taxable income.   Once again, as their withholding agent, Bill is
        also liable  for the amounts which he withheld from their pay, as
        authorized by  W-4 certificates  that were  lawfully and  validly
        executed.   The tax is actually paid by the "person made liable",
        that is, Bill Conklin.
        
        
             Incidentally, the  above Sections  are  listed  in  the  IRC
        definition of "withholding agent", as follows:
        
        
             (16) Withholding Agent.  --  The  term  "withholding  agent"
             means any  person required  to deduct  and withhold  any tax
             under the provisions of section 1441, 1442, 1443, or 1461.
        
                                                  [26 U.S.C. 7701(a)(16)]
                                                         [emphasis added]

          
             John, maybe  I should  withdraw my original claim and submit
        another one  for the  full $50,000  amount.   This is  my  formal
        notice to you that I have reserved my right to do so, even though
        and regardless  of the  fact that  I have already filed one claim
        for $1 of this reward.
        
             As I  write this, I must add that my colleague John C. Alden
        just now  informed me that recent N.C.B.A. literature admits that
        withholding agents  are specifically  defined by  statute  to  be
        liable for  federal income taxes.  For the record, I have not yet
        read your  literature on  this subject,  and honestly heard about
        the literature for the first time from John C. Alden.
        
             Thank you very much for your consideration.
        
        
        Sincerely yours,
        
        
        
        
        /s/ Mitch Modeleski, Founder
        Account for Better Citizenship
        
        
        copies:   John Pleasant
                  Brett Brough
                  other interested parties



        MEMO
        
        TO:       John C. Alden, M.D.
        
        FROM:     Mitch Modeleski, Founder
                  Account for Better Citizenship
        
        DATE:     June 7, 1992
        
        
        Let's combine  two recent  analyses into  one:   the  "liability"
        question and The Matrix "chain" of logic.
        
        It is  interesting that the only "person" actually made liable by
        the statute is a withholding agent.
        
        When  you  go  to  the  sections  listed  in  the  definition  of
        "withholding agent", the term "nonresident alien" is mentioned.
        
        When you go to the definition of "nonresident alien", the term is
        defined as "not a citizen" and "not a resident".
        
        The terms  "citizen" and "resident" are entirely dependent on the
        meaning of "United States".
        
        The definition  of "United States" is dependent on the meaning of
        "District of Columbia" and the "States".
        
        The definition of "States" is dependent on the meaning of the
        "District of Columbia" and "include".  And so on.
        
        Notice how  the thread from "liability" takes you right back down
        the same  path already  traversed in  my original  claim  to  the
        $50,000 reward.   It's like a pile of spaghetti, only the strands
        merge.
        
        That is,  "include" may  be expansive,  but it can only encompass
        territory over which the "United States" is sovereign.
        
        For purposes  of acquiring citizenship at birth, a person is born
        subject to  the jurisdiction  of the "United States" if his birth
        occurs in  territory over  which the "United States" is sovereign
        (from Am Jur).
        
        We end up at the same place  --  sovereignty  --  which vaults us
        into the  domain of  the study entitled Jurisdiction over Federal
        Areas within  the States  (see  Chapter  11  and  also  Becraft's
        excellent brief on jurisdiction).
        
        As you  may already  know, there is a large number of cases which
        define the  res judicata  of sovereignty.   We are right where we
        want to be!


        
        MEMO
        
        TO:       John C. Alden, M.D.
        
        FROM:     Mitch Modeleski, Founder
                  Account for Better Citizenship
        
        DATE:     May 28, 1992
        
        SUBJECT:  Sovereignty and The Matrix
        
        
             I want  to try  some logic on you;  it's an extension of the
        matrix logic  discussed in  The Federal  Zone.    Let's  use  the
        following schema, in order to develop a "chain" of logic:
        
                                c    a
                              +---------+                 
                            R | Rc | Ra | R
                              |----+----|
                            N | Nc | Na | N
                              +---------+
                                c    a
        
        Use capital  letters to  identify one matrix dimension, and small
        letters to identify the other matrix dimension.
        
             Now, take  an index  card and cover up row 1 (the "Resident"
        row).   This leaves only row 2 (the "Nonresident" row), columns 1
        and 2.   If you are a "Nonresident", then it is important to know
        whether you are a "citizen" or not.  If you are a "citizen", then
        you are  an "Nc"  and you pay tax on your worldwide "income".  If
        you are  not a  "citizen", then you are an "alien" and you are an
        "Na".  The definition of "citizen" is therefore pivotal.
        
             Now, move  the index  card so  it covers  only column 2 (the
        "alien" column).   Whether you are a "Resident" citizen ("Rc") or
        a "Nonresident" citizen ("Nc"), you are still a "citizen" and you
        pay tax  on your  worldwide  "income"  regardless  of  where  you
        "Reside".  The definition of "citizen" is again pivotal.
        
             Once again, move the index card so it covers only row 2 (the
        "Nonresident" row).   Whether you are a Resident "citizen" ("Rc")
        or a  Resident "alien" ("Ra"), you are still a "Resident" and you
        pay tax  on your  worldwide "income"  regardless of  your status.
        Now the definition of "Resident" becomes pivotal.
        
             Finally, move the index card so it covers only column 1 (the
        "citizen" column).   If  you are an "alien", then it is important
        to know  whether you  are a  "Resident" or  not.   If you  are  a
        "Resident", then  you are  an  "Ra"  and  you  pay  tax  on  your
        worldwide "income".   If  you are not a Resident, then you are an
        "Na".  The definition of "Resident" is again pivotal.
        
             We deduce  from the  above that the definitions of "citizen"
        and "Resident"  are both  pivotal.   Are  these  two  definitions
        related in  any way?   Yes,  they both  refer to  the same thing,
        namely, the  "United States".   If you are not a "citizen" of the
        "United States",  then you  are an  alien  with  respect  to  the
        "United States".   If  you are  not a  "Resident" of  the "United
        States", then  you are  a Nonresident with respect to the "United
        States".   The definitions of "citizen" and "Resident" thus pivot
        around the same term:  "United States".
        
             Although Becraft's essay does an excellent job of describing
        the jurisdiction  of the  "United States", it lacks the necessary
        rigor to  define precisely  the status  of its  "citizens".  As a
        result, his  discussion of  tax "subjects" is vague and confusing
        (e.g., "aliens  here, citizens  abroad").   This  is  surprising,
        since our  logic proves  that the  terms "citizen" and "Resident"
        both  pivot   around  the   meaning  of   "United  States",   the
        jurisdiction of  which Becraft  appears to understand quite well,
        but the  citizens of which Becraft appears to misunderstand.  His
        confusion might  have been eliminated by better research into the
        exact definition of "citizen".
        
             Compare his  discussion of  tax "subjects"  with the  key we
        have found in