The Federal Zone: Appendix J: Petitions to Congress

Appendix J

Petitions to Congress

Reader's Notes:

Text of Prepared Statement

Read Aloud at Community Meeting

Sponsored by Representative Barbara Boxer

Paul Andrew Mitchell, Founder

Account for Better Citizenship

August 22, 1990

Dance Palace

Pt. Reyes Station, California

Good Evening, Representative Boxer. My name is Paul Mitchell. I want to thank you for inviting us to this gathering, and for your statement to us here tonight. I have listened with undivided attention to what you have said. I have come here tonight to ask that you now give me your undivided attention, and that you answer honestly, yes or no, the simple question I will put to you at the end of my brief statement. Representative Boxer, I formally present to you substantive evidence that the 16th Amendment to the Constitution of the United States was never lawfully ratified. I present to you substantive evidence that a massive fiscal fraud has been perpetrated by the federal government upon the people of this land, a massive fiscal fraud that began in the year 1913 and continues until today. And so, I will put to you this simple question. Please honor my question by answering YES or NO. Do you, or do you not, support the abolition of federal taxes on personal income sources?

MEMO

TO: Friends, Neighbors, Colleagues

and all interested parties

FROM: Paul Andrew Mitchell, Founder

Account for Better Citizenship

DATE: January 1, 1991

SUBJECT: Enclosed Letter to Rep. Barbara Boxer

I am writing to share with you a copy of my recent long letter to Congresswoman Barbara Boxer, my representative in the Congress of the United States. If you will please find the time to read the entire letter, I am confident you will agree that it documents numerous reasons for coming to the following conclusions about our federal government:

1. Wages are not taxable income, as the term is defined by several key decisions of the U.S. Supreme Court that remain in force today.

2. The U.S. Constitution authorizes Congress to levy "direct taxes" on private property, but only if those taxes are apportioned across the 50 States.

3. The IRS now enforces the collection of "income taxes" as direct taxes without apportionment, and cites the 16th Amendment for its authority to do so.

4. The 16th Amendment, the "income tax" amendment, was never lawfully ratified by the required 36 States, but was declared ratified by the U.S. Secretary of State.

5. The 16th Amendment could never have done away with the apportionment rule for any direct taxes if it never became a law in the first place.

Please feel free to duplicate this memo and the attached letter to Representative Barbara Boxer, in any quantity you wish.

If you wish to write to me, please use the address found on the first page of my letter to Rep. Boxer.

Thank you for your consideration.

REGISTERED U.S. MAIL: c/o general delivery

Return Receipt Requested San Rafael, California

Postal Zone 94901/tdc

December 24, 1990

Rep. Barbara Boxer

House of Representatives

United States Congress

Washington, D.C. 20515

Dear Representative Boxer:

With this letter, I formally petition you for redress of a major legal grievance which I now have with the federal government of the United States of America. At your community meeting in Pt. Reyes Station last fall, you agreed publicly, in front of several hundred witnesses, to examine the evidence against the 16th Amendment to the U.S. Constitution. Since I have not heard from your office on this matter, I am writing this letter to remind you of your promise, and to remind you also of your oath of office, by which you swore to uphold and defend the Constitution of the United States of America, so help you God.

I do understand how the crisis in Iraq has succeeded in changing your priorities and distracting you, your staff, and your colleagues from other pressing national issues. At your recent community meeting at the College of Marin, you chose to limit public discussion to the reasons for and against a Congressional declaration of war against Iraq. I must admit, to the extent President Bush sought to preempt the front page with his offensive military maneuvers, he has been almost entirely successful in that endeavor. Barbara, you must understand that the problems with the 16th Amendment, and they are many, will not go away simply because the President, the Courts, or the Congress wish them away.

A terribly confusing and fearful situation has arisen out of the fact that the Supreme Court has, on several occasions, clearly defined what constitutes "taxable income", whereas Federal District and Appellate Courts have, for at least the last ten years, chosen to ignore the relevant Supreme Court decisions and to include wages in their definition of taxable income. As a result of decisions by these lower courts, people have been imprisoned and their homes and other assets have been forcibly taken from them. Moreover, the Federal courts have consistently refused to admit into evidence any of the 17,000 State-certified documents which have been assembled against the 16th Amendment.

These same lower courts cite the case of Brushaber v. Union Pacific Railroad, among others, in support of their conclusion that the 16th Amendment has been declared constitutional by the U.S. Supreme Court. To add to the confusion, federal tax experts like Irwin Schiff and Otto Skinner cite this same Supreme Court in support of their conclusion that the 16th Amendment did not change any of the taxing powers already found in the U.S. Constitution. For example, Schiff has written the following:

Another fallacy promoted by the government and the legal establishment is that the Sixteenth Amendment amended the Constitution. The Brushaber Court, however, clearly explained that, in reality, the Sixteenth Amendment did not alter the taxing clauses of the Constitution. ...

Here the Court pointed out that any belief that the 16th Amendment gave the government a new, direct taxing power (not limited by either apportionment or the rule of uniformity) would "cause one provision of the Constitution to destroy another", and "if acceded to ... would create radical and destructive changes in our constitutional system."

[from The Great Income Tax Hoax, Hamden, 1984]

[Freedom Books, pages 182-183, emphasis added]

Author Otto Skinner relies, in part, on the Supreme Court decision in Stanton v. Baltic Mining Company which reads:

... the provisions of the Sixteenth Amendment conferred no new power of taxation[,] but simply prohibited the previous complete and plenary power of income taxation[,] possessed by Congress from the beginning[,] from being taken out of the category of indirect taxation[,] to which it inherently belonged[,] and being placed in the category of direct taxation subject to apportionment.

[quoted in The Best Kept Secret, San Pedro, Calif., 1986]

[Otto U. Skinner, emphasis and commas added for clarify]

Contrast these cases with the following statement published in the Federal Register, Vol. 39, No. 62, March 29, 1974, in the section entitled "Department of the Treasury, Internal Revenue Service, Organization and Functions", which reads as follows:

(2) Since 1862, the Internal Revenue Service has undergone a period of steady growth as the means for financing Government operations shifted from the levying of import duties to internal taxation. Its expansion received considerable impetus in 1913 with the ratification of the Sixteenth Amendment to the Constitution under which Congress received constitutional authority to levy taxes on the income of individuals and corporations.

[emphasis added]

I have several serious problems with this statement, which was published in the Federal Register by Donald C. Alexander, Commissioner of Internal Revenue at that time. First of all, the IRS now defines "income" to include wages. Using the above quote, the IRS cites the 16th Amendment for its authority to levy taxes on wages. Nevertheless, this definition of income flatly contradicts the definition of income found in several key Supreme Court decisions. Specifically, the Brushaber court wrote the following in their decision to uphold the constitutionality of the 16th Amendment:

Moreover in addition the conclusions reached in the Pollock Case did not in any degree involve holding that income taxes generically and necessarily came within the class of direct taxes on property, but on the contrary, recognized the fact that taxation on income was in its nature an excise entitled to be enforced as such ....

[Brushaber v. Union Pacific Railroad, 240 U.S. 1]

[emphasis added]

Can there be any doubt that taxes on wages are "direct taxes on property"? District and Appellate courts have repeatedly sided with the IRS by ruling that "income" is anything that "comes in". In doing so, these same courts flatly contradict earlier Supreme Court decisions on the very same subject. Take the case of Southern Pacific Company v. John Z. Lowe, Jr., 247 U.S. 330, which decided as follows:

We must reject in this case ... the broad contention submitted in behalf of the Government that all receipts -- everything that comes in -- are income within the proper definition of "gross income" ....

Another Supreme Court decision which defined what constitutes "taxable income" is Emanuel J. Doyle v. Mitchell Brothers Company, 247 U.S. 179. In defining "income", this decision stated that:

... it imports, as used here, something entirely distinct from principal or capital either as a subject of taxation or as a measure of the tax; conveying rather the idea of gain or increase arising from corporate activities.

Another Supreme Court case, Stratton's Independence v. Howbert, 231 U.S. 406, issued yet another official definition of "income" as follows:

This court had decided in the Pollock Case that the income tax law of 1894 amounted in effect to a direct tax upon property, and was invalid because not apportioned according to population as prescribed by the Constitution ... for "income" may be defined as the gain derived from capital, from labor, or from both combined ....

Without question, the most significant Supreme Court case to define "income" was Mark Eisner v. Myrtle H. Macomber, 252 U.S. 189, commonly known as Eisner v. Macomber. In the following long passage, pay particular attention to the explicit intent of the Supreme Court in wording its decision the way it did:

In order, therefore, that the clauses cited above from Article I of the Constitution may have proper force and effect ... it becomes essential to distinguish between what is and what is not "income," as the term is there used; and to apply the distinction, as cases arise, according to truth and substance, without regard to form. Congress cannot by any definition it may adopt conclude the matter, since it cannot by legislation alter the Constitution, from which alone it derives its power to legislate, and within whose limitations alone that power can be lawfully exercised.

... Here we have the essential matter -- not a gain accruing to capital, not a growth or increment of value in the investment; but a gain, a profit, something of exchangeable value proceeding from the property, severed from the capital however invested or employed, and coming in, being "derived," that is received or drawn by the recipient (the taxpayer) for his separate use, benefit and disposal -- that is income derived from property. Nothing else answers the description.

... A proper regard for its genesis, as well as its very clear language, requires also that this [16th] Amendment shall not be extended by loose construction, so as to repeal or modify, except as applied to income, those provisions of the Constitution that require an apportionment according to population for direct taxes upon property real and personal. This limitation still has an appropriate and important function, and is not to be overridden by Congress or disregarded by the courts.

[emphasis added]

In another Supreme Court case, Merchant's Loan & Trust Company v. Smietanka, 255 U.S. 509, note in particular that the definition of "income" was considered to be "definitely settled" as follows:

... with the addition that it should include "profit gained through a sale or conversion of capital assets," there would seem to be no room to doubt that the word must be given the same meaning in all of the Income Tax Acts of Congress that was given to it in the Corporation Excise Tax Act and that what that meaning is has now become definitely settled by decisions of this court.

In determining the definition of the word "income" thus arrived at, this court has consistently refused to enter into the refinements of lexicographers or economists and has approved, in the definitions quoted, what it believed to be the commonly understood meaning of the term which must have been in the minds of the people when they adopted the Sixteenth Amendment to the Constitution. ...

Notwithstanding the full argument heard in this case and in the series of cases now under consideration, we continue entirely satisfied with that definition, and, since the fund here taxed was the amount realized from the sale of the stock in 1917, less the capital investment as determined by the trustee as of March 1, 1913, it is palpable that it was a "gain or profit" "produced by" or "derived from" that investment, and that it "proceeded," and was "severed" or rendered severable, from, by the sale for cash, and thereby became that "realized gain" which has been repeatedly declared to be taxable income within the meaning of the constitutional amendment and the acts of Congress.

Accordingly, after reviewing all the relevant federal court decisions for the past 80 years, constitutional tax expert and author Jeffrey A. Dickstein has written the following to summarize his findings:

Income has been defined by the United States Supreme Court to be a profit or gain derived from various sources, such as labor and capital. A tax directly on the source is a direct tax, and must still be apportioned. A tax on the income derived from the source need not be apportioned. Labor, the labor contract, and the right to sell labor have all been held by the Supreme Court to constitute property. The procedure to determine if there is a gain derived from the sale of property has been set forth by Congress. Gain is derived only if one receives over and above the fair market value of the cost of the property. These basic principles are simple to state and simple to apply. They also lead to one inescapable conclusion:

WAGES DO NOT CONSTITUTE INCOME.

... You must be cautioned that not filing a return with the Internal Revenue Service could result in the imposition of civil penalties and/or the recommendation for criminal prosecution. This illegal conduct on the part of our Executive Department of government is yet but another in a long line of abuses, similar to those which resulted in the Declaration of Independence. It is nonetheless my contention that provisions contained in the United States Constitution, together with decisions of the United States Supreme Court, fully support the legal conclusion that wages do not constitute income as shown in previous chapters, and reinforce the position that the Internal Revenue Service is violating the law in its administration of the personal federal income tax, with the full consent of the federal judiciary.

[from Judicial Tyranny and Your Income Tax, Missoula]

[Custom Prints, 1990, pages 277- 280, emphasis added]

Return now to the statement by IRS Commissioner Donald C. Alexander in the Federal Register in 1974. Under the 16th Amendment, "Congress received constitutional authority to levy taxes on the income of individuals and corporations." Even if the 16th Amendment had been properly ratified by three-fourths of the 48 States in 1913, the Supreme Court has repeatedly defined "taxable income" to be a "gain or profit", not wages or fair compensation for labor. The Supreme Court has never included wages in its several definitions of "taxable income" nor in its interpretations of the 16th Amendment. If that had ever been the intent of the 16th Amendment, or of the Framers of the original Constitution, don't you think the Supreme Court would have said so by now? The Supreme Court has certainly had plenty of opportunities to do so, and they have not done so. Wages for labor were not invented yesterday.

Consider now the situation that arises from a 16th Amendment that was never properly ratified. I am not going to bother here with spelling errors, or with differences in the capitalization of the word "State", that occurred in various resolutions presented to the state legislatures. I am referring, instead, to important, official acts which directly affect the legality of the 16th Amendment, including the vetoes of governors and a State court decision which struck down the Resolution. Note the situation that obtained in Illinois, as quoted from The Law that Never Was, by Bill Benson and M. J. 'Red' Beckman:

In Ryan v. Lynch, 68 Ill. 160, a certificate of the Secretary of State purporting to give full and true copies of the journals of the senate and house relating to the passage of the bill was in evidence and did not show that the bill was read three times on three different days nor passed on a vote of the ayes and noes, as required by the constitution, and the court said that the bill never became a law and was as completely a nullity as if it had been the act or declaration of an unauthorized assemblage of individuals.

In People v. Knopf, 198 Ill. 340, the court again stated the rule that if the facts essential to the passage of a law are not set forth in the journal the conclusion is that they did not transpire, and if the journal fails to show that an act was passed in the mode prescribed by the constitution the act must fail.

[page 52]

Nevertheless, U.S. Secretary of State Philander Knox declared Illinois to be one of the States which ratified the 16th Amendment.

In Arkansas, Governor George W. Donaghey vetoed Senate Joint Resolution No. 7, the proposed 16th Amendment, and the Arkansas Legislature failed to override his veto. According to the provisions of Article VI, Section 16 of the Arkansas State Constitution:

Every order or resolution in which the concurrence of both houses of the General Assembly may be necessary, except on questions of adjournment, shall be presented to the Governor, and before it shall take effect, be approved by him; or being disapproved, shall be repassed by both houses, according to the rules and limitations prescribed in the case of a bill.

When confronted with this serious matter, namely, a governor's veto and the failure of a state legislature to override his veto, the Solicitor of the Department of State wrote the following:

Ratification by Arkansas. Power of the governor to veto.

It will be observed from the above record that the Governor of the State of Arkansas vetoed the resolution passed by the legislature of that State. It is submitted, however, that this does not in any way invalidate the action of the legislature or nullify the effect on the resolution, as it is believed that the approval of the Governor is not necessary and that he has not the power to veto in such cases.

[quoted in The Law that Never Was, page 22]

"It is believed that the approval of the Governor is not necessary and that he has not the power to veto in such cases." Note, in particular, who is making this statement. It is not a judge; it is not a law maker; and it is not a law. The person is a staff lawyer in the Department of State, an organization with no authority whatsoever to make laws or to render official interpretations of law. Making federal law is a power reserved for the Congress of the United States. Rendering final, official interpretations of law is a power reserved for the Supreme Court of the United States. Here, we have the case of a ministerial agent rendering a highly important legal opinion, and a wrong one at that, in a matter affecting the Constitution of the United States, the supreme law of the land. And his opinion was allowed to stand. This is an abomination!

I do not pretend to have any power to foresee the future, particularly in matters affecting the politics of legal interpretation. Nevertheless, with that said, the IRS and the federal government in general face a number of difficult political and legal problems, should the ratification of the 16th Amendment ever be overturned. Quite obviously, the IRS will no longer be able to cite this Amendment as the means "under which Congress received constitutional authority to levy taxes on the income of individuals and corporations." It will need to find, or create, some other authority to levy taxes on the "income" of individuals and corporations. But this is a lot easier said, than done.

With or without a 16th Amendment, the IRS must deal with a long series of Supreme Court decisions which consistently define "taxable income" to be something quite other than wages. More to the point, the Supreme Court has also ruled that "Congress cannot by any definition it may adopt conclude the matter, since it cannot by legislation alter the Constitution." This means that neither the IRS nor Congress have the authority to define "income" any old way they want. This applies to you too, Barbara Boxer, as an elected member of the House of Representatives and as a private citizen. Under the Constitution of the United States, the IRS has never been empowered to make any laws in this area. Those seeking to re-define "income" to include wages will need to persuade the Supreme Court to overturn all previous decisions to the contrary, including decisions which investigated in depth the relevant issues and history of direct taxes, indirect taxes, and defining income.

Assuming for the moment that it was properly ratified, there remains a serious debate, both inside and outside the federal judiciary, as to whether the 16th Amendment authorized an unapportioned direct tax on "income", or whether it authorized an excise entitled to be enforced as an indirect tax. The Pollock Case supports the idea that federal income taxes are direct taxes. The Brushaber Case supports the idea that federal income taxes are indirect taxes. Contrary to Supreme Court rulings, the IRS defines income to include wages, and cites the 16th Amendment as its authority for imposing direct taxes on wages without apportionment. Accordingly, some legal scholars conclude that the 16th Amendment did amend the Constitution, while others conclude that it did not. A properly pleaded Supreme Court decision would hopefully settle the several issues in this particular debate; it would serve to determine which rule applies to "federal income taxes" -- apportionment for direct taxes, uniformity for indirect taxes, or neither -- and to provide a credible justification for this determination.

To illustrate the range of disagreement on such a fundamental constitutional issue, consider the conclusion of legal scholar Vern Holland:

It results, therefore: ...

4. That the Sixteenth Amendment did not amend the Constitution. The United States Supreme Court by unanimous decisions determined that the amendment did not grant any new powers of taxation; that a direct tax cannot be relieved from the constitutional mandate of apportionment; and the only effect of the amendment was to overturn the theory advanced in the Pollock case which held that a tax on income, was in legal effect, a tax on the sources of the income.

[The Law that Always Was, Tulsa, 1987, F.E.A. Books, p. 220]

Now consider an opposing view. After much research and much litigation, author and attorney Jeffrey A. Dickstein offers the following clarification:

A tax imposed on all of a person's annual gross receipts is a direct tax on personal property that must be apportioned. A tax imposed on the "income" derived from those gross receipts is also a direct tax on property, but as a result of the Sixteenth Amendment, Congress no longer has to enact legislation calling for the apportionment of a tax on that income.

[ibid., pages 60-61, emphasis added]

We must be careful not to put the cart before the horse, however. Like it or not, this debate cannot proceed any further without squarely facing 17,000 State-certified documents impugning the entire ratification process of the 16th Amendment. This means that citizens and lawmakers together must confront our current situation "as if the bill never became a law and was as completely a nullity as if it had been the act or declaration of an unauthorized assemblage of individuals." Chicanery is not synonymous with good law. Specifically, even if this were its specific intent, the 16th Amendment could never have done away with the apportionment requirement on any direct taxes if it never became a law in the first place. Without question, the IRS is now enforcing the collection of income taxes as direct taxes without apportionment, and cites the 16th Amendment as its authority to do so.

Without the 16th Amendment, Congress does retain its original authority to levy two great categories of taxes -- direct taxes and indirect taxes -- an authority it always had. Without the 16th Amendment, direct taxes are constitutional, and therefore legal, if and only if they are apportioned across the several States. Taxes on wages, or on all of a person's gross receipts, are direct taxes on personal property which must be apportioned, and are illegal and unconstitutional if they are not. Moreover, failing the 16th Amendment and using Dickstein's logic as a guide, taxes on the "income" derived from those gross receipts are also direct taxes on property, and must also be apportioned. Without the 16th Amendment, indirect taxes are constitutional, and therefore legal, if and only if they are uniform across the several States. To the extent that the IRS, and any other branches of the federal government, should violate these rules, they are violating the supreme law of the land and thus violating individual rights which that supreme law was explicitly established to guarantee.

One way out of this dilemma for the federal government is to begin immediately to apportion taxes levied on wages and other gross receipts of individuals, and to demonstrate to the Supreme Court that the totals obtained from the various States are proportional to their respective populations. Irwin Schiff describes in simple language how this could be done. Another way out of this dilemma is to begin immediately to impose income taxes as "excise taxes" on corporate profits, and to demonstrate to the satisfaction of the Supreme Court that the resulting tax rates are uniform across the States. For example, it is entirely within the power of Congress to impose an "income tax" on the profits of the Federal Reserve Corporation, since that corporation is not an agency of the federal government, and is currently exempted from income taxes by an act of Congress.

By themselves, neither of these are very likely to happen, or be very easy to enforce if they do happen, should the 16th Amendment be overturned, and should its overturning receive the widespread publicity it is likely to receive. If the 16th Amendment is overturned, the people will, for better or for worse, rejoice that "income taxes" have been declared unconstitutional and, as currently administered by the IRS, they would be right.

To resolve any lingering doubts, the Supreme Court should be presented with an opportunity to determine squarely the constitutionality of a general tax on gross receipts without apportionment. According to scholar Vern Holland, a properly pleaded case has never been brought before the high Court. Holland asserts that the bulk of historical evidence allows for only one conclusion:

The Court cannot ignore the weight of evidence that proves that a General Tax on Income levied upon one of the Citizens of the several States, has always been a direct tax and must be apportioned.

[ibid., page 220]

The best alternatives available to the federal government are to abandon direct taxes on wages entirely, to shift instead to a greater reliance on excise taxes, and to reverse its policy of debt financing. The machinery for administering excise taxes is already in place for taxing the sale of commodities like gasoline. Abolishing withholding taxes will eliminate a huge, involuntary burden on the vast working classes of America, and restore incentive to a working place badly in need of all the motivation it can muster. It will also put the lie to the IRS claim that federal "income" taxes are voluntary, all the while employers are forced to withhold the wages of employees who are told repeatedly they have no choice in the matter.

Moreover, there is much evidence to suggest that lowering taxes would have the effect of stimulating the economy in a disproportionate, economically "elastic" way. For example, see "Higher Taxes Aren't the Answer -- History Proves it," by Stephen Moore, Reason Foundation, Santa Monica, CA, October 1990. By abolishing "wage taxes" and relying instead on excise taxes levied upon commercial transactions, the government raises more money as the economy improves, and raises less money as the economy declines, giving government a strong incentive to "tune" its excise taxes accordingly. I am prepared to share with you some excellent proposals for financing the federal government entirely thru a national sales tax.

This is a far cry from our present situation, in which the federal government is fast approaching total bankruptcy, and cannot balance its budget without simultaneously raising taxes further still and reducing spending even more so. Because it employs so many people at present, and buys so many goods and services, the federal government is central to the American economy. Thru the vehicle of debt financing, the federal government now grows at the expense of the economy, plunging future generations into ever higher debt, and ever larger interest payments. At the rate we are going, it is only a matter of months before the interest payments alone on the national debt will exceed the entire annual tax revenues to the U.S. Treasury.

It is becoming increasingly difficult to hide a trillion dollar savings and loan scandal. The Federal Savings and Loan Insurance Corporation (FSLIC) is basically broke. The Federal Deposit Insurance Corporation (FDIC) now has only $4 billion to cover some $2 trillion in bank deposits. Thus, the federal insurance fund covers only one-fifth of one percent of total deposits (i.e. 4 / 2000). The FDIC will fail when only a small number of banks collapse. Call these the "first wave". Lacking any federal insurance at that point, a second wave of bank failures will cause millions of Americans to lose their bank deposits forever, and possibly also lose the millions of home mortgages on which those deposits are leveraged. By itself, isn't this enough to convince you how serious is our national fiscal crisis?

Representative Barbara Boxer, I implore you to exercise your powers as an elected official in the Congress of the United States, to examine carefully the mountain of evidence against the 16th Amendment, to investigate the many consequences of declaring it null and void, and to study the many alternative ways of financing the federal government without direct taxes on the gross receipts of individuals. You have a number of legal options available to you, including the power to subpoena documents and witnesses before Congressional committees. You have it within your power to authorize such committees to investigate charges of fraud and other illegal tampering with the procedures for amending the Constitution of the United States, the supreme law of our land. You have it within your power to examine all the actions of federal government officials involved in declaring the 16th Amendment "ratified" in the year 1913, because there is no statute of limitations on fraud. And you have it within your power to include the American public in a process of open hearings, public education and free discussion on this subject, as you did so wonderfully at the College of Marin to discuss a declaration of war.

Representative Barbara Boxer, I stand ready, willing, and able to help you in any way I can to investigate further the charge of felony fraud which I now make to you:

THE SIXTEENTH AMENDMENT WAS NEVER LAWFULLY RATIFIED.

Sincerely yours,

/s/ Paul Andrew Mitchell, Founder

Account for Better Citizenship

enclosures: computer analysis of evidence

against the 16th Amendment