TO:       David K. Smith
          Oklahoma Tax Commission
          State of Oklahoma
          c/o 2501 Lincoln Blvd.
          Oklahoma City 73194-0001/tdc

FROM:     Paul Andrew, Mitchell, B.A., M.S.
          Counselor at Law

DATE:     June 2, 1997

SUBJECT:  Agreement on Coordination of Tax Administration
          between Oklahoma Tax Commission and "IRS" [sic]

I have  recently come to possess a photocopy of your Agreement on
Coordination of Tax Administration, executed between the Oklahoma
Tax Commission and the Internal Revenue Service, as requested and
received by a Citizen of Oklahoma state on May 16, 1997.

In Section 2: Definitions, We find the following definition:

     2.2  IRS  The term "IRS" means the Internal Revenue Service,
     U.S. Department of the Treasury [sic].

                                            [bold emphasis added]

Please provide  Us with  the exact  citation(s) within  Title 31,
United States  Code, which authorize the Internal Revenue Service
to exist  as a department or bureau within the U.S. Department of
the Treasury.  Our reading of Title 31 tells Us that the Internal
Revenue Service is not listed among those subordinate bureaus and
departments, unlike  the Bureau  of Engraving and Printing, which
is listed therein.  See 31 C.F.R. 51.2 and 52.2 for regulations.

Please also  take note  of the  fact that Title 31, United States
Code ("U.S.C."), has been enacted into positive law, rendering it
conclusive evidence  of the statutes in question.  By comparison,
Title 26,  U.S.C., has  not been enacted into positive law, which
means that  Internal Revenue  Code ("IRC")  section 7851(a)(6)(A)
now controls the applicability of all of subtitle F of the IRC --
Procedure and Administration.

The term  "this title"  as that term is used at IRC 7851(a)(6)(A)
refers to  Title 26, U.S.C.  For proof, compare, in pari materia,
the Historical  and Statutory Notes following 28 U.S.C. 132, with
the original  Act dated  June 25, 1948, C. 646, Sections 2 to 39,
62 Stat.  985 to  991, as  amended, specifically  under the  sub-
heading "Continuation of Organization of Court" [sic].

While you  are investigating your answer to this question, please
allow Us also to refer you specifically to the California Supreme
Court case  of  People v. Boxer,  docket number  S-030016,  dated
December 1992.  See Full Faith and Credit Clause for authority.

Thank you very much for your consideration.

Sincerely yours,

/s/ Paul Andrew, Mitchell, B.A., M.S.

Counselor at Law and federal witness
c/o 2509 N. Campbell Avenue, #1776
Tucson 85719/tdc



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