Wikipedia:Mediation Cabal/Cases/2007-10-21 Tax protester

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Wikipedia Mediation Cabal
Article: Tax protester
State: Closed

Requested By: Mpublius 19:53, 21 October 2007 (UTC)
Other Parties: Famspear, Arthur Rubin, Morphh, MPublius, BD2412
Mediated By: Aeon
Comments: Case is now closed due to inactivity.



Contents

[edit] Request details

Resolve dispute about the definition of "tax protester."

[edit] Who are the involved parties?

[edit] What's going on?

To advance a biased political agenda, the word "protester" is being used to describe people who do not protest anything. Webster's Dictionary and Black's Legal Dictionary are being rejected in favor the definition of blogger Daniel Evans.

[edit] What would you like to change about that?

Remove the first paragraph and retain the definitions of Webster and Black.

[edit] Mediator notes

Case Opened at 17:40, 30 October 2007 (UTC) and acepted by Æon Insanity Now!

Article and statements are currently under review and I will begin the mediation process within the next 24 to 48 hours. Æon Insanity Now! 17:40, 30 October 2007 (UTC)

Statements reviewed and a quick glance at the past conduct of all editors has been done. Article review and dif review to follow. Æon Insanity Now! 18:12, 30 October 2007 (UTC)

Article has been reviewed and the following noted: The Article is a part of the United State Taxation Wikiproject and therefore covers parts U.S. Taxation Law.

Article Rating by Project: Start Article Priority for Project: High

Has the issue been discussed on Article Talk Page: Yes and at length.

Once Mpublius has had a chance to confrim mediation we can begin. Case is on hold until then. Æon Insanity Now! 18:32, 30 October 2007 (UTC)

Mpublius has contacted me mediation is open. Sorry for the Delay. Æon Insanity Now! 18:31, 2 November 2007 (UTC)

[edit] Administrative notes

[edit] Discussion

[edit] Statement by MPublius

“Tax protester” means someone who protests a tax, as indicated by Webster's dictionary, stating, “a declaration by a payer, esp. of a tax, that he does not concede the legality of a claim he is paying.” Similarly, Black's Legal Dictionary states:

The formal statement, usually in writing, made by a person who is called upon by public authority to pay a sum of money, in which he declares that he does not concede the legality or justice of the claim or his duty to pay it, or that he disputes the amount demanded; the object being to save his right to recover or reclaim the amount, which right would be lost by his acquiescence. Thus, taxes may be paid under "protest.”

The word “protester” cannot be properly used in the English language to describe someone who does not declare a protest, such as the contradictory definitions in the first paragraph by Bruce Hochman, arguing that it applies to, "persons who claim the tax laws are unconstitutional or otherwise invalid, and who therefore fail to file a tax return or file returns with no income or tax data supplied” and Daniel Evans, who applies “tax protester” those who, "refuse to pay taxes or file tax returns out of a mistaken belief that the federal income tax is unconstitutional, invalid, voluntary, or otherwise does not apply to them under one of a number of bizarre arguments"

Leaving aside the vagueness of whatever constitutes a “bizarre argument”, a protester requires an affirmative declaration by the protester of the supposed protest. Bad writing is not merely aesthetically unpleasant and disingenuous in its discussion of politics, it is morally wrong. As former IRS historian Shelley Davis, who testified at the Senate Finance Committee Oversight Hearing on the Internal Revenue Service stated:

A tax protester, in my definition, is not someone who may oppose our system of taxation, but pays his taxes nonetheless. A tax protester is not someone who says that our tax system is broken and must be dismantled, but still files a Form 1040. A tax protester is not someone who merely criticizes the IRS. A tax protester is not someone who challenges an IRS assessment. But in the mind of the IRS, all of the above ideas fit the unofficial IRS profile of a tax protester. In the cloistered environment of the IRS, criticism of the IRS, or the income tax, equals tax protester.

The government, Daniel Evans, and some Wikipedia editors are destroying the English language to advance a biased political agenda. As George Orwell stated in his essay, Politics and the English Language, the fifth rule of good writing is, “never use a foreign phrase, a scientific word, or a jargon word if you can think of an everyday English equivalent.” Wikipedia editors should let the facts speak for itself, rather than endorse government jargon that deliberately destroys the English language. Mpublius 17:38, 26 October 2007 (UTC)

[edit] Statement by Famspear

Before we get deeply into this, my question to my fellow editors is: Is there a valid reason we are supposed to go through all this again?

User Mpublius has been pushing his/her crusade against the use of the term "tax protester" for weeks now. For starters, see the article and talk page for Tom Cryer. The details of his/her arguments keep changing, but the substance of what is going on here will be obvious to editors who review the edit history of Mpublius.

Mpublius at first objected to the very use of the term "tax protester" in a Wikipedia article. Mpublius was first unable to persuade Wikipedia editors that the term "tax protester" should not be used.

After having had numerous court cases cited to him, and after I myself added the Black's and Webster's dictionary defintions to show Mpublius (and indeed all readers) that the term "tax protest" (and by extension "tax protester") has more than one formal legal meaning, Mpublius transparently changed his/her tactic. He/she began a crusade to delete the references to the meanings discussed in the Wikipedia articles as used by the Federal courts (essentially, the Hochman and Evans "frivolous tax arguments" definitions) and to retain the separate Black's and Webster's dictionary definitions, the effect of which would be to give readers a false impression about how the legal system -- the courts in particular -- use the term "tax protester" today in a particular way to describe frivolous, repeatedly rejected arguments about Federal income taxes.

Each of the related Wikipedia articles discusses the phenomenon of "tax protesters" as that term is used by Evans, by Hochman, and by the Federal courts in income tax cases.

The articles are not talking about the earlier Black's and Webster's meanings of the term. I have successfully argued non-frivolous "tax protests" (in the Black's and Webster's sense) on behalf of clients on local property tax issues. I have filed non-frivolous written "protests" (in the Black's and Webster's sense) with the IRS on behalf of clients after the issuance of an IRS thirty-day letter. The Blacks' and Webster's definitions do apply to those kinds of protests. Those kinds of protests have nothing to do with what the Wikipedia articles are discussing.

To reiterate: The Wikipedia articles discuss the meaning of the term "tax protester" as currently used by the Federal courts (i.e., in the Hochman and Evans sense) to describe wild, frivolous, totally nonsensical arguments about Federal income tax law that have been rejected in Federal courts over and over and over -- without one single exception in over 200 years. The subject of the Wikipedia articles is the phenomenon of frivolous Federal income tax litigation and frivolous positions taken on Federal income tax returns, etc., and not the kind of "tax protest" described in Black's and Websters.

I urge all interested parties to read the history of the term "tax protester" in the article Tax protester and to carefully review the edit history of Mpublius, especially in the Tom Cryer article and talk page, and in other tax-related articles and talk pages.

At what point is Mpublius going to accept consensus? Famspear 03:10, 22 October 2007 (UTC)

PS: I am, of course, prepared to go into more substantive detail, complete with appropriate citations.

I suggest that Wikipedia editors are entitled at this point to some explanation from Mpublius as to why we are still having to discuss this point. I also suggest that Wikipedia editors are entitled to some materially new argument from Mpublius, and not another rehash of the same thing. Famspear 03:22, 22 October 2007 (UTC)

[edit] Statement by BD2412

While I appreciate Famspear's exasperation, I'll just get straight to citations from the majority of the United States Federal Courts:

  • "The Internal Revenue Service ("IRS") filed a Notice of Federal Tax Lien on Marino's property relative to her income tax liability for the 1996 tax year. On October 29, 2002, a Collection Due Process ("CDP") hearing was held, at which Marino contested her underlying income tax liability. She made arguments which the IRS settlement officer informed her had been consistently rejected as groundless by the courts. For example, she asserted that she was not liable for the income tax, that she did not have to file returns, that the Internal Revenue Code was unconstitutional, and other similar "tax protester" arguments. The IRS settlement officer gave her a copy of Pierson v. Commissioner, 115 T.C. 576 (2000), which warns taxpayers about sanctions for frivolously opposing the collection of taxes."
    • Marino v. Brown, 357 F.3d 143, 144 (1st Cir. 2004).
  • "At their root, Allamby's claims rest on long-rejected "tax protester" arguments that the federal income tax is unconstitutional and that wages are not taxable income.
    • Allamby v. United States, 207 Fed. Appx. 7 (2d Cir. 2006)
  • "Defendant-Appellant Robert E. Nolen, a persistent "tax protester," was convicted on three counts of willfully attempting to evade the federal income tax in violation of 26 U.S.C. § 7201. On appeal, he contends that (1) the district court violated his Sixth Amendment rights when it revoked the pro hac vice admission of his retained counsel, (2) the evidence at trial was insufficient to establish the charged offense, because no tax obligation had been formally assessed, (3) the district court committed plain error by failing to require the jury to find an affirmative act other than willful failure to file returns and by failing to require the jury to find exactly the same affirmative act of evasion that was charged in the indictment, and (4) the district court erred by ordering restitution in a case arising under Title 26 of the United States Code.
    • United States v. Nolen, 472 F.3d 362, 367 (5th Cir. 2006).
  • "And insisting that an attorney raise silly, frivolous defenses is not a sign that a defendant is acting in good faith. Urging that a lawyer offer the kind of run-of-the-mill arguments offered by tax protesters is strong evidence of conduct which can be viewed as a waiver of Sixth Amendment rights."
    • United States v. Murphy, 469 F.3d 1130, 1136 (7th Cir. 2006).
  • "In this case, we find that the Israels have filed a frivolous appeal raising tax-protester arguments which have been repeatedly rejected in numerous other proceedings, including some involving the Israels. Moreover, the district court repeatedly warned the Israels that continuing to press such patently frivolous arguments would likely result in sanctions. In these circumstances, we conclude that sanctions are appropriate. See United States v. Gerads, 999 F.2d 1255, 1256-57 (8th Cir. 1993) (per curiam) (when appellant brought frivolous appeal based on tax protester argument, court granted government's motion for sanctions)."
    • Israel v. IRS, 210 Fed. Appx. 549, 550 (8th Cir. 2006)
  • John Anthony Malan ("Milan") was convicted of criminal contempt under 18 U.S.C. § 401(1) for statements he made to several prospective jurors in a trial involving a nationally-known tax protester.
    • United States v. Milan, 215 Fed. Appx. 597, 598 (9th Cir. 2006).
  • "Mr. Chisum argues that he was extremely prejudiced by evidence of his lawsuits against tax judges. He asserts that the evidence portrayed him as a tax protester and that it added nothing relevant because the district court had already admitted the tax judges' opinions finding his trusts to be shams."
    ...
    "Mr. Chisum contends that the district court erred in denying his motions to dismiss for lack of jurisdiction. He claims that the federal district court for the Eastern District of Oklahoma is "incapable of acting by Article III judicial powers within the State of Oklahoma's sovereign territory and without the federal zone." Aplt. Br. at 26-27. Our review is de novo. See Mires v. United States, 466 F.3d 1208, 1209 (10th Cir. 2006). We rejected this "hackneyed tax protester refrain" 17 years ago in United States v. Collins, 920 F.2d 619, 629 (10th Cir. 1990), and we do so again today. The district court did not err in denying Mr. Chisum's motions to dismiss for lack of jurisdiction."
    • United States v. Chisum, 2007 U.S. App. LEXIS 22742, 1, 13-14. (10th Cir. 2007). Note that this case was decided about three weeks ago, so it amply demonstrates the currency of this use of the term.
  • "Plaintiff Lindsey Springer, a tax protester, describes himself as the founder of "Bondage Breakers Ministries," organized in 1992, whose sole purpose is "to expose the violations of the written law committed by the Internal Revenue Service [(IRS)]." R., Doc. 1 at 5, P 9."
    • Springer v. IRS ex rel. United States, 231 Fed. Appx. 793, 795 (10th Cir. 2007).
  • "In 1996, Ward Dean, a medical doctor, published author, and retired naval flight surgeon, became a tax protester. He had always paid his federal income taxes faithfully up to this point, but on his 1040EZ tax form for 1996, Dean suddenly reported his income and his tax liability as "0." At the time, Dean was earning over $ 100,000 a year as the Medical Director for Vitamin Research Products and drawing down roughly $ 36,000 a year through his navy pension. Although Dean's accountant, John Graham, prepared a 1996 return and a 1997 return that reflected Dean's true earnings and his tax liability, Dean refused to file these returns and substituted 1040EZ forms that stated he owed nothing in taxes. Dean also submitted a revised W-4 form to his employer, claiming that he was exempt from federal income tax withholding for 1997."
    • United States v. Dean, 487 F.3d 840, 844 (11th Cir. 2007). Like most of the people discussed in the cases above, Dr. Dean is currently serving a lengthy jail term for tax evasion.

So, let's see, that's the 1st, 2nd, 5th, 7th, 8th, 9th, 10th, and 11th Circuits. All using the term "tax protester" in exactly the way the article describes. I'm sleepy, I'll get citations from the 3d, 4th, 6th, and Federal Circuits tomorrow. Cheers! bd2412 T 05:53, 22 October 2007 (UTC)

Oh, and:

  • I. "Tax Protester"

    Bergman contends that he was prejudiced at trial because the Government continuously referred to him as a "tax protester." He argues that the references were prejudicial because they associated him with a conspiratorial group of lawbreakers and deprived him of presenting a willfulness defense. We disagree.

    The term "tax protester" accurately characterizes Bergman's activities. His objections to filing tax returns, based principally on the Fifth Amendment, have been rejected repeatedly by this court. United States v. Malquist, 791 F.2d 1399, 1402 (9th Cir.), cert. denied, 479 U.S. 954, 107 S. Ct. 445, 93 L. Ed. 2d 394 (1986); United States v. Smith, 735 F.2d 1196, 1197 (9th Cir.), cert. denied, 469 U.S. 1076, 83 L. Ed. 2d 514, 105 S. Ct. 574 (1984); United States v. Carlson, 617 F.2d 518, 522-23 (9th Cir.), cert. denied, 449 U.S. 1010, 101 S. Ct. 564, 66 L. Ed. 2d 468 (1980). References to Bergman's "tax protest" activities were also probative of his willfulness in violating the tax laws. Carlson, 617 F.2d at 523-24; see also United States v. Booher, 641 F.2d 218, 221 (5th Cir. 1981). Consequently, we agree with other courts that have found the term "tax protester" a permissible shorthand reference to such activities. See, e.g., United States v. Turano, 802 F.2d 10, 12 (1st Cir. 1986).
    • United States v. Bergman, 813 F.2d 1027, 1029 (9th Cir. 1987).

Cheers again! bd2412 T 05:59, 22 October 2007 (UTC)

As promised, here are citations from the 3rd, 4th, 6th, and Fed. Circuits:

  • "Thurston Paul Bell is a professional tax protester who ran a business and a website selling bogus strategies to clients endeavoring to avoid paying taxes. In the 1980s, he worked for Save-A-Patriot, an entity dedicated to the proposition that "American citizens are not liable for the income tax."
    ...
    Here, the District Court found that Bell's speech was both misleading and that it promoted unlawful activity. Like the several other courts faced with similar claims from tax protesters, the District Court found that Bell's "U.S. Sources" interpretation of the tax code is "nonsensical" and frivolous, rests "purely on semantics" and "takes the regulations promulgated under Section 861 [of the Internal Revenue Code] out of context."
    • United States v. Bell, 414 F.3d 474, 475, 480 (3d Cir. 2005).
  • "John R. Peeples, Jr., a "tax protester," appeals from a Tax Court decision upholding an Internal Revenue Service (IRS) deficiency determination for taxable years 1980 and 1981 and a district court decision sustaining a $500 civil penalty assessed as a result of Peeples' 1982 tax return. ... The record indicates that Peeples filed tax returns for 1980 and 1981 which contained the word "refused" on all lines which called for his occupation, items of income, adjustments, credits, payments, other taxes, tax computation, and tax owed or refund due. Above his signature, Peeples explained his refusals were based on the Fifth Amendment..."
    • Peeples v. Commissioner, 771 F.2d 77, 78 (4th Cir. 1985).
  • "In his memorandum opinion, the Tax Court judge sustained the Commissioner's deficiency determination in the amount of $ 13,976, finding that Sawukaytis had "advanced shopworn arguments characteristic of tax-protester rhetoric that has been universally rejected by this and other courts."
    • Sawukaytis v. Comm'r, 102 Fed. Appx. 29, 31 (6th Cir. 2004).
  • "King's appellate brief is chiefly a rambling collection of "tax protester" dogma..."
    • United States v. King, 1994 U.S. App. LEXIS 34295 (6th Cir. 1994).
  • As a result of the interview with Dougherty, the inspector interviewed Mattson, who acknowledged that Dougherty had advised her that her son-in-law had forged an income tax return which generated a tax refund that Dougherty's daughter was not aware of, and that she needed to obtain her daughter's tax return. According to Mattson, Dougherty also said that her son-in-law's tax return had been prepared by the known tax protester Robert Graham.
    • Mattson v. Department of the Treasury, 86 F.3d 211, 213 (Fed. Cir. 1996).

And here is the Sixth Circuit quoting the Tenth Circuit at length:

  • To put the argument to rest, we quote the following from a Tenth Circuit opinion in which the court was responding to an identical tax-protester argument.
    ...
    [Defendant]'s motion to dismiss advanced the hackneyed tax protester refrain that federal criminal jurisdiction only extends to the District of Columbia, United States territorial possessions and ceded territories. ... Efforts to argue that federal jurisdiction does not encompass prosecutions for federal tax evasion have been rejected as either "silly" or "frivolous" by a myriad of courts throughout the nation. In the face of this uniform authority, it defies credulity to argue that the district court lacked jurisdiction to adjudicate the government's case against defendant.
    . . .
    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 v. Union Pac. R.R., 240 U.S. 1, 12-19, 36 S. Ct. 236, 239-42, 60 L. Ed. 493 (1916); efforts to argue otherwise have been sanctioned as frivolous.
    • United States v. Mundt, 29 F.3d 233, 237 (6th Cir. 1994) quoting United States v. Collins, 920 F.2d 619, 629 (10th Cir. 1990) (citations omitted), cert. denied, 500 U.S. 920, 114 L. Ed. 2d 108, 111 S. Ct. 2022 (1991). Note that the "cert. denied" part means that the tax protester whose arguments failed in Collins tried to get his case heard before the U.S. Supreme Court, which declined to hear the case.

And here is the Federal Circuit laying down its general rule imposing sanctions against frivolous tax protester arguments:

  • This is a manifestly frivolous appeal which never should have been taken. There was no arguable way of confronting Judge Yock's indisputable holdings that his court had no jurisdiction, and, as we have noted, Zuger's substantive position has been universally rejected by many courts. Zuger himself appears to be a veteran "tax protester." He was convicted in the District of Connecticut of willfully failing to file income tax returns, and the Second Circuit characterized his appeal from that conviction "as completely frivolous." He has thus had fair warning that he cannot attack the federal tax and monetary system by abusing the courts.
    ...
    Accordingly, we impose, under Rule 38, Federal Rules of Appellate Procedure, a sanction of $ 500 against Zuger. We also warn that we shall likewise impose sanctions in any future "tax protester" case in which the appeal is frivolous and an unwarranted burden on the court and the Government.
    • Zuger v. United States, 834 F.2d 1009, 1010 (Fed. Cir. 1987).

And, as a bonus, here is a case from the United States Court of Federal Claims:

  • Because, notwithstanding plaintiffs' legal gyrations, the Sixteenth Amendment now permits the levy of income taxes without apportionment, and wages are indeed income subject to taxation. These types of arguments, commonly made by tax protesters such as plaintiffs, have been rejected, flatly and uniformly, by other courts, and are rejected by this court as well. See, e.g., Ledford v. United States, 297 F.3d 1378 (Fed. Cir. 2002); United States v. Connor, 898 F.2d 942 (3d Cir. 1990); United States v. Hanson, 2 F.3d 942 (9th Cir.1993); Connor v. Commissioner, 770 F.2d 17 (2d Cir. 1985); Lovell v. United States, 755 F.2d 517 (7th Cir. 1984); Ficalora v. Commissioner, 751 F.2d 85 (2d Cir. 1984); Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 99 L. Ed. 483, 75 S. Ct. 473 (1955).
    • Hamzik v. United States, 2003 U.S. Claims LEXIS 394, 4-5 (Ct. Cl. 2003).

In closing, the above citations from every Federal Circuit in the U.S. demonstrate that the phrase "tax protester" means (at least in the U.S. Federal Courts) one who makes frivolous and discredited arguments that income tax need not be paid because it is unconstitutional, because the federal government has no power over states, because it is a form of self-incrimination, and so forth. Cheers once again. bd2412 T 13:19, 22 October 2007 (UTC)

[edit] Statement by Arthur Rubin

I wasn't notified of this proposed mediation, only of two others by Mpublius, but I concur. The definition Mpublius wants is, at best, historical. It could be (and is, as noted by Famspear) referenced in the article, but one one who makes a "tax protest" is no longer called a "tax protester", except by those who are "tax protesters" and want to confuse the issue. — Arthur Rubin | (talk) 09:17, 22 October 2007 (UTC)

[edit] Statement by Morphh

The article is about the topic in which tax protester is currently defined (of which is the use in the U.S. legal system). This should be the main definition - it is accurate, sufficiently sourced, and significant with regard to weight. One consideration - the article is about U.S. tax protesting but does not reflect it in the article title, which may open the term up to broader globalized usage. Although I don't know of any other primary usage outside the U.S. The definition pushed by Mpbulius is included in the article under 'Derivation of the term "tax protester" from the legal term "protest"', which may deserve its own article with regard to the process described above by Famspear and could be referenced under this definition. The expanded section may be giving more weight to this definition (in this article) than it deserves, which essentially means someone who challenges an IRS assessment. There is also a loose slang usage which calls a tax protester someone who may oppose our system of taxation, but pays taxes nonetheless. Someone who says that our tax system is broken and must be dismantled, but still files or someone who merely criticizes the IRS. We have a couple media references for that. The weight to include these definitions is in the range of tiny minority (and not the topic address in the article) but their inclusion (as shown by this discussion) may be warranted to prevent disputes. I'm against replacing the definition suggested by Mpublius as the primary definition. It wouldn't make sense for this article. Morphh (talk) 15:31, 22 October 2007 (UTC)

[edit] Link to prior discussion on this topic

Here is a link to the prior discussion on this topic: [1] Yours, Famspear 19:43, 22 October 2007 (UTC)

Here is an earlier crusade by Mpublius on his/her dislike of the use of the term "tax protester" to describe people who make legally frivolous arguments. This started as an effort to delete the use of the term "tax protester" to describe Tom Cryer, at [2] with the Mpublius statements: "There is no third party source for the defamatory claim that Cryer is a tax protester. The government press release announcing the case does not engage in derogatory schoolyard name-calling."

Then, when a third party source was added (from legal commentator Daniel B. Evans), Mpublius goes on to try to have that removed, attacking Evans and calling Evans a "blogger" and an "enemy" of Cryer.

See also: [3].

and see: [4], where Mpublius refers to the very use of the term "tax protester" in the article as being an "Orwellian nightmare":

"This article is an Orwellian nightmare. Wikipedia does not exist to promote government propaganda. I didn't make up the words “tax” and “protester”; both are perfectly serviceable words that existed long before I was born. It's the government that has mashed the two together to form a completely different meaning intended to mislead readers."

And see: [5].

And this: [6].

and the rest of the talk page on the Tom Cryer article.

Mpublius has offered no rational explanation as to (1) why Wikipedia should not have articles that accurately report situations where people like Tom Cryer, who clearly and obviously make frivolous arguments about Federal income taxation, are explicitly referred to by reliable third party sources as being "tax protesters," (2) why Mpublius believes, as he/she apparently does believe, that the Federal courts should not use the term "tax protesters" to describe such people (see quoted material above), (3) why legal scholars such as Evans or Hochman should not be considered reliable sources accurately reporting that the courts do use the term in this way, (4) why the verbatim texts of court decisions themselves should not be considered reliable sources showing that the courts do use of the term in this way (see the copious citations by editor BD2412 above, and citations in related articles such as Tax protester constitutional arguments, Tax protester statutory arguments, and Tax protester conspiracy arguments), (5) why Wikipedia should not be allowed to accurately show, in Wikipedia articles, how third party authorities including the courts use the term -- not in the Blacks/Websters sense, but instead in the Evans/Hochman frivolous arguments sense.

Due to the efforts of Mpublius since August, the dispute between Mpublius and other editors on the use of the term "tax protester" (and on the very definition of "tax protester") has been discussed to death. The processes of RfCs and mediations would seem to mean little where Mpublius, not having obtained what he/she wants, merely asks for more such processes after a few weeks' interval. I would argue that the time for closure with respect to Mpublius' requests for comments and mediation, etc., about the use and definition of "tax protester" -- to accurately describe a person who makes legally frivolous arguments about Federal tax law -- is long overdue. At some point, we need to have closure and move on. Yours, Famspear 20:29, 22 October 2007 (UTC)

[edit] The saga continues

No response from Mpublius here. Now, it's back to Tom Cryer -- as Mpublius has now requested arbitration on that article:

[7]

Yours, Famspear 17:09, 26 October 2007 (UTC)

OK, I see that Mpublius has now responded here. Famspear 17:57, 26 October 2007 (UTC)