Wages/Receipts Not Income (NTR) - The individual argues that salaries and wages are not "income" within the meaning of the Sixteenth Amendment, which grants Congress the power to "Lay and collect taxes on income, from whatever source derived..:" The individual could also argue that labor worth a certain amount is exchanged for money worth the same amount and therefore there is no income to be taxed.

Eisner v. McComber- The individual reports wages but deducts them as "non-taxable compensation/remuneration" referencing Eisner v. McComber. The individual may alter line items showing non-taxable compensation or non-taxable receipts to back out some or all of their income, generally resulting in a zero tax liability.

Zero Returns (ZERO) - The individual submits a return with zero money amounts on all or most of the line items on the form, e.g., an individual may enter zeros for income and deductions but enter an amount of tax withheld and request a refund of that amount.. A statement may be attached claiming there is no section of the Internal Revenue Code that established an income tax liability. The statement may also contain arguments regarding the definition of income. There are several variations on this type of filing such as those bearing the words "nunc pro tunc" and "not liable." See also item 42 in this list.

U.S. v. Long (Z-LONG) - The individual submits a return with zero money amounts. To explain the zeros inserted on the form, the individual references to "U.S. v. Long" .

Not a Citizen/Free Citizen/Not a Resident of Federal Zone - The individual argues they are not a citizen of the United States and receive no income or benefits from sources within the United States. May file a Form 1040NR to receive a refund of withheld income tax or claim citizenship of a " State Republic" . Alternatively, the individual may claim that he or she does not live in a federal Area Office or zone (Area Office of Columbia, Guam, Puerto Rico, the Virgin Islands, the Northern Marianna Islands, and certain other "possessions, enclaves, and trust territories " ). NOTE: The aforementioned does not apply to a foreign person who has paid withholding inadvertently and has filed a claim for a refund.

Reparation Tax (REPTX) - The individual submits a return, an amended return, or correspondence referring to a reparation settlement based on the impact of slavery, or may refer to black taxes, reparations for African-Americans, or 40 acres and a mule. It may also include a Form 2439 with fictitious RIC such as Investment Taxes or Department of the Treasury.

Form 2555 Deduction (F2555) - The individual submits a return showing income then deducts that same amount (or a large portion of that amount) by adding "Form 2555" to line 21. Form 2555, Foreign Earned Income, is usually attached showing the individual's address in the United States as the foreign address. The individual also shows his income on Form 2555 as "foreign earned income" even though his employer's address is also in the United States. Correspondence may be attached arguing the term "income" and stating that each of the several states are foreign countries. NOTE: Frivolous Forms 2555 should be worked in the FRP area at the receiving Campus rather than forwarded to PSC.

Not a "Person" or "Individual (NTINDV) " - The individual argues he or she is not a "Person" or "Individual" within the meaning of the Internal Revenue Code and is therefore not subject to income taxes.

Sixteenth Amendment (16AMEND) - The individual argues the Sixteenth Amendment was not properly ratified and therefore the federal government does not have the legal authority to collect an income tax without apportionment. Generally the argument focuses on matters such as inconsistencies in versions ratified by the various states.

Fifth Amendment (5AMEND) - The individual makes an improper blanket assertion of the Fifth Amendment right against self-incrimination as a basis for not providing any financial information.

Altered Jurat/UCC 1–207 (JURAT) - The individual submits a return that contains income and deductions but the jurat has been altered or stricken. May include reference to UCC 1–207 or a statement that the return was not signed under penalties of perjury. The alteration may be located elsewhere on the return with an arrow pointing to the jurat. There may be an explanation on the return or attachments reflecting the desire to negate the effect of the jurat by showing the taxpayer did not intend to file a return in good faith.

Altered Form (ALTFORM) - The individual submits a return altering any or all line items with the intent of facilitating non-compliance with the tax laws.

Unsigned Returns (UNSIGN) - The individual completes a return but fails to sign. A statement why the return is not signed may be attached or added to the return indicating, among other arguments, disagreement with the tax system.

Wages Deducted in Cost of Goods Sold (F-SCHC) - The individual submits a return with a Schedule C attached claiming a deduction which is equal, or nearly equal, to the amount reported as wage income. The deduction is usually included in the cost of goods sold but could appear under a different deduction category.

Valuation (FAIRMV) - The individual argues that income is not taxable because of the declining fair market value of the dollar, because the dollar is not backed by gold/silver, because the value of services is offset by the value of the labor (barter income), etc.

In Lieu of (ILO) - The individual submits a document captioned, Statement in lieu of U.S. income tax Form 1040. Various other arguments may be used in the document.

Disclaimer (DISCL) - The individual submits documentation which contains a disclaimer. The disclaimer states the individual, "disclaims the liability for the tax due" , making the liability on the return zero. This disclaimer may be a part of a return, on a return attachment, or in other documents.

Protest Against Government Action/Inaction (WARTAX) - The individual argues that their refusal to file a return or pay tax is justified because they disagree with government policies or spending plans. The individual may claim deductions or credits because of an objection to having his or her taxes used to support various government activities.

Taxes are Voluntary/Law Does Not Require (VOLUN) - The individual submits a return, amended return, or correspondence that argues income taxes are voluntary.

Challenges to Authority/Title 26 or "law" in Other Documents (CONST) - The individual may argue that Title 26 of the United States Code is not law because it was never enacted as named. As a separate position, the individual may argue that other laws or documents prevent the IRS from assessing and collecting tax. This argument may reference the Bible, Bill of Rights, Declaration of Independence, Magna Carta, Northwest Ordinance, Declaration of Resolved, Federalist Papers, Mayflower Compact, Articles of Confederation of 1788, Declaration of Rights of 1765 and 1774, and others.

Challenges to Authority/Due Process (VOFPOV) - The individual questions various administrative authorities such as delegation orders, summons authority, privacy act, etc. This argument may be based on contentions that Treasury Department Orders (TDOs) were not published in the Federal Register, that the Commissioner lacked authority to propose regulations, that TDOs, Regulations, Treasury Decisions, Forms, and other actions and activities do not comply with the Paperwork Reduction Act, Privacy Act, Administrative Procedures Act, and Federal Register Act. The individual may argue that they must be afforded a hearing or a trial before taxes can be assessed or before property can be seized.

Internal Revenue Service is a Private Organization/Collects Tribute, Not Taxes (TRIBU) - The individual argues that the IRS is an entity named the Internal Revenue and Tax Service, Inc. which was incorporated in Delaware in 1933. The individual further argues that since the IRS deposits its revenues in the Federal Reserve Bank, it is a collection agency for the bank, which is in the business of making loans and conducting proprietary business, thereby removing the cloak of governmental immunity. Additionally, they argue the Department of Treasury is part of the United Nations and is clandestinely leading the tax-paying public into a "new world order" .

Alleged Churches/First Amendment (ALDGCH) - The individual receives income from non-religious sources and may claim a vow of poverty. The individual submits a return where all, or substantially all, of the gross income is claimed as a deduction on Schedule A of the return.

Amended Returns/Form 843 Claim for Refund and Request for Abatemet(AMEND) - The individual files an amended return or a Form 843 to obtain a total refund of all taxes paid in prior years, based on a tax avoidance argument not supported by law.

Untaxed (UNTAX) - The individual argues that he or she should be "untaxed" and attempts to drop out of the Social Security system. He or she will withdraw or rescind his or her SSN, claiming he or she is a sovereign citizen.

Federal Reserve Notes Are Not Legal Tender (FEDRES) - The individual argues that their wages are not taxable because they were paid in federal reserve notes. He or she argues that notes are not valid currency or legal tender and, thus, those who possess them cannot be subject to a tax on them.

Services Not Taxable/Thirteenth Amendment/Form of Servitude (13AMEND) - The individual argues that income results only from the sale of goods, and therefore, the value of services is not taxable. This includes indentured servitude arguments and barter offsets. The individual may also argue that the Thirteenth Amendment outlawed slavery. He or she may claim to be "natural unfranchised individuals and freemen" who are residents of states, and therefore nonresident aliens for the purpose of the Internal Revenue Code.

Obscene, Vulgar, Harassing (OBSC) - The individual submits documents or other materials indicating that non-filing is due to dissatisfaction with tax policies or taxation in general. Often, this argument is expressed with obscene, vulgar, or crude language and characters in an extremely demeaning manner.

Other — All others not specifically defined.

Non-negotiable Chargeback (NNCB) - The individual attempts to sell his/her birthright back to the government for a large dollar amount and requests that a "Treasury Direct Account" be set up to hold the money.

IRC 861 for Individual Employees (IMF861) - The individual files a return or claim stating that wages are not taxable based on CFR 1.861 and requesting a refund of all federal withholding.

IRC 3121 (FICA) - The individual contends that IRC 3121 exempts the Federal Insurance Contribution Act (FICA) portion of earnings from the definition of wages and therefore from gross income for federal tax purposes. The individual attempts to reduce taxable income by his/her portion of withheld social security tax.

1041 - Lifetime Social Security Claims (LFTMEARN) - The individual claims a refund for all social security paid during their lifetime. Taxpayer requests a "lifetime earnings statement" from Social Security Administration in order to list the amount of withheld social security taxes as federal income tax or other payments.

1041 - In Lieu of 1040 (1041ILO) - The individual deducts personal income as fiduciary fees or other deductions on Form 1041 resulting in a zero tax liability.

IRC 1341 - Claim of Right (COR) - The individual claims " Compensation for personal labor" is not taxed by Title 26, IRC Section 1341, and takes a deduction on Schedule A or removes the amount from gross income.

Bosnian Refugees (BOSNREF) - The individual attempts to eliminate tax liability by filing Form 1040X removing their tax on line 10 (Total Tax) and citing under Part II that they are entitled to refunds based upon their status as Bosnian refugees.

Not Liable (NTLIABL) - The individual submits returns or claims with "Not Liable" printed on the return. The returns also reflect zero money amounts.

IRC 861 Business - Employment Tax (BMF861) - This argument targets employers and advises them that wages are exempt from withholding. Based on CFR 1.861, promoters of this scheme advise employers to stop withholding and paying payroll taxes on their employee's wages. In addition, some employers file amended payroll tax returns and request refunds of previously paid payroll taxes.

EIC with Disability Income (FRIVEIC) - The individual reports disability income as the sole source of income to claim earned income credit but does not attach a Form W-2 or Form 1099.

Exempt Employees of World Bank Organization (XMTEMP) - The individual files a return with a statement attached which asserts, "World Bank Employee - Wages not Subject to Income and/or Non-Taxable Income - World Bank." The individual lists an adjustment equal to the amount of the wages and claims adjusted gross income is zero. May also cite IRC Section 893 which provides a tax exemption to some employees of international organizations.

American Indian Treaty (AMERIND) - The individual attempts to eliminate tax liability by filing forms 1040 removing their income on line 21 (Other Income) and citing, "less Native American Indian Treaty" or "Native American Indian Treaty." The returns usually include Form 1099 MISC or other income documents that include withholding which can result in a refund of withholding credit.

Nunc Pro Tunc (NUNC) -The individual attempts to eliminate tax liability by filing returns citing "Nunc Pro Tunc" somewhere on the return. The return usually consists of all zeros except withholding and generally a refund is claimed. No further justification for the zero return is given. "Nunc Pro Tunc" is Latin for "Now for Then" . These taxpayers appear to want the IRS to accept the frivolous return they have filed in place of what they filed previously.

IRC 1001 (1001) - The individual attempts to eliminate tax liability by filing forms 104X removing all or part of income as an itemized deduction on Schedule A, "Other Miscellaneous Deductions" and citing, "IRC 1001: even exchange of property-Labor(property)-Employer's(property). NO GAIN REALIZED. Butcher's Union Co. v. Crescent City Co., 111 US 746 S. CT. Rptr.. pp. 660-661."

any individual files what purports to be a return of the tax imposed by subtitle A but which --(A) does not contain information on which the substantial correctness of the self-assessment may be judged, or (B) contains information that on its face indicates that the self-assessment is substantially incorrect; and

the conduct referred to in paragraph (1) is due to --(A) a position which is frivolous, or (B) a desire (which appears on the purported return) to delay or impede the administration of Federal income tax laws, then such individual shall pay a penalty of $500.

The return must contain sufficient data to calculate a tax liability, and

must purport to be a return, and

must include an honest and reasonable attempt to satisfy the requirements of the tax law, and

must be signed under penalties of perjury. (Generally the jurat must be unaltered.)